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  • Mon. Aug 15th, 2022

Startup Marketing? How Honesty Can Boost Your Success

Apr 15, 2022
Startup Marketing? How Honesty Can Boost Your Success

Soho Workspaces Inc. and our affiliates (collectively “The Farm,” “we,” “us,” or “our,”) care about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how The Farm collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), applications, or other services that refer to or link to this Policy, as well as any offline products, programs, courses, and services (collectively our “Services”). 

The Farm has many affiliated entities that act as data controllers around the world who will act as the data controller for your Personal Information, and your Personal Information may therefore be shared with entities outside of the jurisdiction in which it was collected. For more information on the data controller for your jurisdiction please review the list of our global entities for the name of the The Farm entity responsible for your Personal Information and the appropriate contact information for that entity.

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 Farm. You can read more about how Personal Information is used by clicking below on the name of The Farm Services, websites, or applications you use.

References to “you.”  In this Policy, “you” means anyone who uses our websites, applications, or other Services. 

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.

COVID-19.   We may collect, use, disclose, and otherwise process your Personal Information in connection with our response to COVID-19.

The Personal Information that we collect, and our use of that information depends on your relationship with us and the requirements of applicable law as described below.

We collect information:

INFORMATION COLLECTED FROM YOU

The Farm 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:

INFORMATION COLLECTED ABOUT YOU

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.

How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:

LEGAL BASES FOR PROCESSING PERSONAL INFORMATION IF RESIDENT IN THE UK AND EU

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 with a secure environment, analyzing, improving, and better tailoring our products and Services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.

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.

We disclose your Personal Information in limited circumstances to The Farm, our community, our service providers and advertisers, other end users, in order to provide our Services and to improve ways of working in our community and where required by applicable law. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent. We will require all parties receiving your Personal Information to take appropriate measures to protect your Personal Information and to process your Personal Information only for the purposes described: 

Landlords and Building Management.  In some cases we may share your Personal Information with our landlords and/or building management at The Farm properties so that they can effectively manage and operate the building.

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.

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:

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). For more information on these types of tracking tools, please see our Cookie Policy. 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-The Farm 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 videos with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the 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 hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.

We value your rights to your data. In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us at [email protected] or at one of the physical addresses set out in the list of global entities top of this Policy.

We will process all such requests in accordance with local laws. To protect your privacy, The Farm 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 may have the right to opt-out or withdraw your consent for  certain uses and disclosures of your Personal Information.

6.1 SENSITIVE PERSONAL INFORMATION

Where you have consented to The Farm’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 Personal Information for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, The Farm 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 Farm will comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

If you would like to make a complaint or if you have any questions about how we use or keep your Personal Information, you may contact The Farm at [email protected] 

If you are based in India you may submit any complaints to our Grievance Officer at: [email protected]

For visitors to our Services you may have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction, if you believe our processing of your Personal Information violates applicable law. 

The Farm 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 contractual 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 at the top of this Policy and below in Section 12.5

We retain the personal information we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

When determining how long this retention period will last once the purpose of processing the Personal Information has been satisfied, we take into account the length of time Personal Information is required to:

The security of all Personal Information provided to The Farm is important to us. The Farm 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. 

By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

11.1 CCTV

The Farm’s buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of The Farm’s employees, members, and guests and their property. These recordings may be accessed by The Farm. The Farm may also make CCTV footage available to members and other third parties authorized by The Farm. 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 may be kept longer where The Farm 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.

The Farm’s CCTV practices are based on an assessment of the data protection interests of affected data subjects against our legitimate interests. 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. The recordings are generally retained for a limited period of time in accordance with Section 9 of this Global Privacy Policy.

11.2 COLLECTION OF INFORMATION FROM CHILDREN

Generally, our 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 has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.

11.3 THIRD PARTIES

This Privacy Policy does not address the privacy, data, services or other practices of any entities other than The Farm, including landlords, building managers, licensees and brokers.

We display advertisements and other content from third parties or partners that link to third-party websites that we do not own or operate. We provide links to these third-party sites as a convenience to you. 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. Additionally, third parties may sell goods or offer services at our facilities or in combination with our Services. We are not responsible for those third parties’ services or their privacy practices.

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-parties     .

11.4 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 “Last Updated” date to indicate when those changes became 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 or 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 Farm.

11.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding this Policy, please contact us at [email protected]

If you would like to contact us in writing, please see our list of global entities at the top of this Policy for contact information of the data controller for your jurisdiction. 

If you are based in a jurisdiction where the law requires that The Farm has a Data Protection Officer, please submit your query to [email protected]

The Farm 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.

California Privacy Rights

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 removed 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)

We have explained our privacy practices in the other sections of this Privacy Policy. In this section, we supplement those descriptions for California residents by providing a list of categories of personal information as set forth in the CCPA that have been collected or disclosed for a business or commercial purpose during the preceding 12 months, as well as certain other information. Please see the other sections of the Privacy Policy for additional information and context.

Category of Personal Information Explanation. 

As discussed in the other sections of our Privacy Policy, we collect this type of information from you, through our interactions with you and others, and from third parties, and we disclose all of these categories of Personal Information within the The Farm companies and our community, to service providers and third-party advertising partners, and as needed to comply with legal process. Your Personal Information may also be shared with third parties with whom you interact and third parties that you direct us to share your information with through our Services, and you may learn about your choices for third-party advertising cookies and similar technologies in our Cookie Policy. 

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, The Farm does not “sell” personal information, nor do we have actual knowledge of any “sale” of Personal Information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Exercising Your Rights 

You may exercise your rights as a California resident by calling +1 (906) 629-1755, or by contacting The Farm at [email protected] 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. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. 

When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth above.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, phone number, and/or mailing address. 

Shine the Light law

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. Requests may be sent to [email protected]

This content was originally published here.