1. Introduction

This Privacy Notice explains how Peerspace, Inc., and each of its subsidiaries (details of which are available by clicking here), (together "Peerspace" or "we") collects, uses, protects and discloses personal information (as defined in Section 2 below) when you use our products and services, our website and online services, and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Notice appears, or otherwise interact with us (together, our "Services") and we are acting as a data controller; when you provide services to us and we collect your personal information in connection with this; and when we collect personal information from third parties. This Privacy Notice does not apply to, and Peerspace is not responsible for, any third-party websites, including any such websites which may be accessible through links from the Services.

If you reside in California, please also see our California Privacy Notice below. By using the Services, you agree to the collection and use of your personal information as described in this Privacy Notice. If you do not agree, please do not use the Services.

Where you use our Services, or your personal data (as defined in Section 2 below) is processed in connection with such Services, and we control the purpose for which such personal data is processed, Peerspace will be the data controller of such information. From time to time, there may be more than one data controller of your information within our group where you have engaged different parts of our broader organization to provide different or jointly delivered services.

This Privacy Notice contains the following sections:

1. Introduction (current section)

2. Information We Collect

3. Legal Basis for Usage of Personal Data

4. How We Use Personal Information

5. How We Disclose Personal Information

6. Retention

7. Security

8. International Data Transfers

9. Your Rights and Choices

10. Online Analytics and Advertising

11. Children’s Privacy

12. Third-Party Sites

13. Changes to This Privacy Notice

14. Contact Us 

15. California Privacy Notice

2. Information We Collect

“Personal data,” “personal information,” and, if the context requires, “information” is any information that identifies you or that we can reasonably link to you. We collect and process certain personal information when you use the Services, including information you directly provide to us and information we collect automatically (e.g., information about your device and use of the Services). We also collect information from third parties such as our vendors. The following table describes the type of information we collect and the source of that information.

3. Legal Basis For Usage of Personal Data

The laws of some jurisdictions, including the EU and UK, require us to state our “legal bases” for using your personal data. Where we use your personal data, we rely on one or more of the following legal bases:

Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, this could be any form of commercial contract to which we are both a party, or if you are a Host and you make Spaces available on the Platform or where you are a Guest and you make a booking on the Platform, and where we respond to your requests and provide you with services in accordance with our Peerspace Services Agreement (“PSA”) or other applicable terms of business agreed with you or with your employing organization.

Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:

• for our own direct marketing or continued communication, subject to your express consent if required in your country of residence;

• the prevention of fraud; our own internal administrative purposes; personalization of the service(s) we provide to you;

• ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or

• reporting possible criminal acts or threats to public security to a competent authority.

Compliance with a legal obligation: We may be required to process your information due to legal requirements, including tax laws and other regulatory provisions applicable to Peerspace.

Consent: You may be asked to provide your consent in connection with certain services that we offer. Where we are reliant upon your consent, you may withdraw this at any time by contacting us, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.

4. How We Use Personal Information

Depending upon the circumstances in which we gather your personal data, we may use your information to provide you with services and information, or for any of the following purposes:

• to provide you with Peerspace’s Services that you or your employing organization request;

• accepting, coordinating, managing, and processing Listings and Bookings;

• facilitating purchase transactions for goods and services;

• providing customer support, accommodations, and personalized services and amenities;

• to respond to your inquiries and maintain and develop our relationship with you;

• engaging in quality control in order to improve our offerings to you;

• facilitating communications between parties;

• to engage in content based or interest-based advertising,

• to provide you on an ongoing basis with information and services, including relevant marketing communications related to Peerspace, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us;

• to evaluate, recruit, and hire personnel;

• ensuring the safety and security of our users, our staff, and all other persons visiting our platform or the properties listed on it, including verifying your identity;

• to prevent, detect, and investigate fraud, cyber incidents, or other illegal activity; communicating with you and others in relation to your use of our services, including providing legal updates;

• administering our record-keeping for legal, tax, and operational purposes;

• exploring new and unique ways to provide products and services; and

• doing our best to fulfill your requests.

We may aggregate and/or de-identify any information we collect through our Services so this information can no longer be linked to you or your device (“De-Identified Information”). We may use De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.    

We may combine the information we collect through the Services with information that we receive from other sources, both online and offline. We may use this combined information subject to this Privacy Policy.  

To learn more about how your personal information is processed for marketing and advertising, please see the section titled “Online Analytics and Advertising” below.

We may not be able to do some or all of these things without your personal data.

If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior information of that new purpose, so you are aware of this.

5. How We Disclose Personal Information

In order to provide you our service and to fulfill our business and commercial purposes, we may disclose your personal information to the different entities and subsidiaries within Peerspace’s group for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organization with services, provided in all instances that such processing is consistent with legal basis for usage of personal data above and applicable law. Information disclosed to facilitate bookings and other interactions between customers, and to enable your use of the Peerspace platform may include demographic information; financial information; government identifiers; protected classification characteristics; transaction history; internet, application, and network activity; location data; sensory (audio data); professional or employment-related information; and inferences about you.

• Publicly Posted Information. Some user information is posted publicly on the platform and is visible by others. This may include profile information, information related to a Space or Listing, reviews, ratings and other feedback, reviews of Guests completing Bookings, reviews of attendees that have attended an event organized by Guests, and other information that a user submits to be posted. Precise location information is not publicly posted.

• Disclosures Between Users. Our Services are designed to connect users and to facilitate interaction between them. We also will disclose your personal information to any agents or third parties to whom you authorize us to disclose it, including the operators, managers, agents, or other parties associated with an Event or when you agree to a Booking. This disclosure is necessary to ensure the performance of the contract between you and Peerspace, and/or you and a third party.

• Our Service Providers: We may disclose your information to our trusted third-party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, insurance providers and third-party administrators, dispute resolution providers, marketing providers, governmental entities, social networks, fraud prevention and detection entities, background verification providers and other users. 

• Other Disclosures. In addition to the foregoing, we may disclose personal information in the following circumstances:

1. If you have consented to us disclosing your personal information in this way;

2. We deem is reasonably necessary to provide you with the services that you have required at any particular time;

3. Such disclosure is to law enforcement bodies or similar governmental authority;

4. Such disclosure is in order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, governmental or local authorities;

5. To exercise and defend legal or payment related claims;

6. When such disclosure is pursuant necessary to protect the rights and freedoms of other individuals, property or safety of Peerspace, Peerspace employees, our clients or others;

7. As part of a prospective or completed merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Peerspace (a “business transaction”); and

8. In any other manner permitted by law, including engaging in protected speech.

• Building Management and Owners: We may disclose personal information of Hosts and Guests such as booking information, physical address, phone number, and information related to compliance with applicable laws and property management agreements with landlords, management companies, and/or property owners to facilitate the Host Services. For example, Guest Booking and personal information, including Guest contact information, may be disclosed to the owner/management, staff, reception, or caretaker of the building, complex, or community where a Host lives and/or the listing is located, to facilitate Host Services, compliance with applicable laws, security, billing, and other services.

We may disclose information that does not reasonably identify you or your organization, including information that has been appropriately de-identified or anonymized, as permitted by applicable law.

6. Retention

We retain the information we collect for no longer than is reasonably necessary to fulfill the purposes that such data was originally collected in accordance with our internal data retention policies or to comply with our legal and regulatory obligations.

7. Security

We are committed to protecting the security of any personal information you provide. We have implemented administrative, technical and physical measures designed to safeguard personal information against theft, loss, and unauthorized access, use, modification, and disclosure. However, the transmission of information via the internet is not completely secure. Please keep this in mind when providing us with your information. You provide us with your information and transmit information over the Internet at your own risk.

You may access and change certain information that you submitted during registration (if you have registered at the Services) at any time by providing your username and password. Please keep your password in a safe place and do not provide this information to anyone. You should use a password unique to Peerspace that is different from any other passwords you use on any other site. We strongly encourage you to check the accuracy of your data regularly as we will use your email, phone number, and home address to communicate with you regarding products or services that you have requested. We will not be liable for any problems or difficulties that arise as a result of your failure to keep your information up to date.

8. International Data Transfers

Peerspace, Inc. is located in the United States and has operational subsidiaries that are located in different jurisdictions in the world, details of which can be accessed here. Information we collect from you will be processed in the United States and other jurisdictions, and the data protection laws in the United States and those other jurisdictions may differ from or provide less protection than the data protection laws where you reside. We take appropriate steps in accordance with applicable law when we transfer your personal information outside of the jurisdiction where you reside.

9. Your Rights and Choices

Marketing Communications. As legally permitted, we may send you marketing communications regarding our Services or the services of third parties that we believe will be of interest to you. Depending on the law of your jurisdiction, you may be able to withhold consent to marketing communications if you so choose. You can ask us to stop sending these communications at any time using the opt-out instructions provided in the communication or by contacting us using the information in the “Contact Us” section below. 

Please note that even if you opt out, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you cannot opt out of certain administrative or transactional emails from us, such as emails confirming your requests or providing you with updates to our Privacy Policy or other terms.

Rights Regarding Your Information. Depending on the jurisdiction where you reside, you may have the right to ask us to:

• Inform you about the types of personal information we collect or disclose about you; the types of sources of this information; the business or commercial purpose for collecting this information; and the categories of third parties to which we disclose this information;

• Provide you access to and/or a copy of certain personal information we hold about you;

• Correct or update personal information we hold about you;

• Delete personal information we have about you;

• Restrict or object to certain uses of your personal information; or

• Opt you out of the processing of your personal information for purposes of profiling that furthers decisions that produce legal or similarly significant effects, if applicable. 

You also have the right to withdraw consent to the processing of your personal information where consent is the legal basis for our processing of such information. Please be aware that if you withdraw consent, in some cases that may prevent us from providing you with certain Services.

Certain information may be exempt from these requests under applicable law. For example, we need certain information in order to provide the Services to you or comply with applicable law.  We may take reasonable steps to verify your identity before responding to a request. Depending on the sensitivity of the information you are requesting and the type of request you are making, this may include verifying your name and email address. If we cannot verify your identity, we may be unable to respond to your requests.  As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. 

If you would like to exercise any of the rights set out in this section, please contact us using the information in the “Contact Us” section below and select “Data Privacy Request” as the contact reason. You may be able to designate an authorized agent to make requests on your behalf. For us to verify an authorized agent, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may verify your identity directly with you before processing the authorized agent’s request, as permitted by applicable law.  

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about making an appeal in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. 

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

Depending on where you live, you may have the right to opt out of “sales” of your personal information and “sharing/processing of your information for targeted advertising.

As explained in the “How We Disclose Personal Information” section above, we may disclose personal information to third-party advertising providers for targeted advertising purposes or use related analytics partners to help us analyze use of our Services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties may be considered a “sale” of personal information or the “sharing”/processing of personal information for “targeted advertising” purposes.

We may disclose your personal information to such third parties through cookies and similar tools for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” or processing for purposes of targeted advertising. To opt out of these disclosures, you can visit this link. Note that you will need to opt out on each device you use to access the Services. If you have a legally recognized browser-based opt out preference signal turned on through your browser, we recognize the preference expressed by this signal in accordance with applicable law. 

10. Online Analytics and Advertising

Online Analytics. We may use third-party web analytics services, such as those of Google Analytics, on our Services. These analytics services help us do many things, including collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; take measures to prevent fraud; provide insights regarding our email marketing; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. 

Tailored Online Advertising. In using the Services, we work with certain third-party advertising technology partners such as ad networks and ad servers. We allow these third parties to place cookies or other similar technologies on the browser of your device to collect information about you (see our Cookies Notice for more information). These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and may access their own cookies or other tracking technologies on your browser to assist in this activity. The following websites provide more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising: the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices. On these websites, you can opt-out of receiving tailored advertising from companies that participate in the programs on these websites. We do not control these opt-out links and we do not control whether our advertising partners participate in these programs. We are not responsible for any choices you make using these programs or links or their continued availability or accuracy.

11. Children's Privacy

Our website and services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 18. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly destroy such information in accordance with applicable law. If you are under the age of 18 (or otherwise under the age of majority in your jurisdiction of residence,) do not use the Services or provide any personal information to us. If you believe that we might have personal information from or about a child under the age of majority, please contact us using the information below.

12. Third-Party Sites

The Services may contain links to websites that are not operated by or for us ("Third-Party Sites") that are provided solely as a convenience to you. If you use these links, you will leave our Services. This Privacy Notice does not apply to Third Party Sites. We have not reviewed the Third-Party Sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Sites listed on or linked to from our website or disclose any of your information via a Third-Party Site, you should understand that you do so at your own risk and should review the third party’s policies for handling information.

13. Changes to this Privacy Notice

From time to time, we may revise this Privacy Notice. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

If we decide to update our Privacy Notice, we will indicate this through the “Last Updated” data at the top of this Privacy Notice. If there are material changes to the Privacy Notice, we will communicate such changes prior to implementing them in accordance with applicable law. Information collected under previous versions of our Privacy Notice will then become subject to the terms of our new Privacy Notice.

14. Contact Us

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us here and select “Data Privacy Request” as the contact reason. Please note, we do not accept consumer rights requests via email.

If you have any questions or comments regarding our privacy practices, or about the manner in which we or our service providers treat your personal information, please contact  [email protected].

15. California Privacy Notice

If you are a California resident, this California Privacy Notice (as updated from time-to-time, this "CA Privacy Notice") explains how we handle your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)) in connection with your use of our Services. This CA Privacy Notice is incorporated in, and in turn incorporates the terms of Peerspace's general privacy policy. Please read this entire CA Privacy Notice carefully to understand our practices regarding your personal information. If you are an employee, agent, contractor, officer, director, or other personnel of Peerspace who resides in California, our handling of your personal information is covered by a separate privacy policy and not by this CA Privacy Notice.

Throughout our Privacy Notice, we discuss in detail the categories of personal information we collect from and about you. The CCPA also requires us to provide the information in the chart below.

We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect your information, and other purposes permitted by applicable law. We retain your personal information as set forth in Section 6, Retention, above.

Right to Opt Out of “Sale” or “Sharing” of Personal Information. The CCPA requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as "sales" even if no money is exchanged. The CCPA also requires us to disclose how we “share” personal information, i.e., how we disclose personal information for purposes of cross-context behavioral advertising (also called targeted advertising). Such activities are described in the chart above.

To opt out of our use of your personal information through cookies and similar technologies for purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes (as indicated in the chart above), you can visit this link. If you have a legally recognized browser-based opt out preference signal turned on through your browser, we recognize the preference expressed by this signal in accordance with applicable law. 

We do not knowingly sell the personal information of minors under 16 years of age.

California Privacy Rights. California residents may make certain requests about their personal information under the CCPA as set forth in “Your Rights and Choices” section above. 

Alternatively, if you are a California resident and would like to exercise your CCPA rights, you may submit your request by contacting our support team: https://support.peerspace.com/hc/en-us/requests/new. You are not required to have an account with us to make a verifiable request.

If we offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

In the limited circumstances that we process sensitive personal information as defined in the CCPA (e.g., log-in information), we only use or disclose it for disclosed and permitted business purposes. Under the CCPA, there is not a right to limit these uses and disclosures.

Shine the Light. California Law allows customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Do Not Track. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.  Do Not Track is different from the legally recognized browser-based opt out preference signal mentioned above.