Effective on: [November 17, 2021].
- Information Collected
- How We Use Your Information
- Web Browser Cookies
- Do Not Track
- Links to Other Sites
- Age of Consent
- CAN-SPAM Compliance Notice
- California Privacy Rights
- California Consumer Privacy Act
- Your Nevada Privacy Rights
- Privacy Information for EU and UK Residents
A. “You” and “your” mean the individual or entity visiting or using the Site. B. “Industrious”, “we,” “us” and “our” means Industrious. C. “Site” refers to Industrious’ website at www.industriousoffice.com, and other related websites, blogs, domains, mobile sites, online services and applications maintained by Industrious. D. “Non-Personal Information” is any information that is not Personally Identifiable Information (defined below). Non-Personal Information includes, without limitation, Personally Identifiable Information that has been anonymized. E. “Personally Identifiable Information” or “PII” is non-public information we receive from your use of the Site that can be used, alone or in combination with other information in our possession, to identify a particular person/individual. It may include information such as name, address, telephone number and other personal information you provide us or that we collect about you. F. “Data” includes both Non-Personal Information and Personally Identifiable Information.
2. Information Collected and Consent
You do not have to provide any Personally Identifiable Information to browse the publicly available pages of the Site, though certain information is collected automatically when you visit the site, as described under “Information We Automatically Collect” . However, in order to obtain or use products or services that are or may be provided on or through the Site or that we may otherwise offer online or offline (collectively, the “Services”) you may be required to register and provide Personally Identifiable Information. We collect some or all of the following categories of information:
a. Information You Provide Us:
We collect your first and last name, title, date of birth, age, gender, mailing address and post code, geographic area, billing address, phone number (landline and/or cellular), occupation, payment information, email address, company, and job title. In certain circumstances we collect copies of government identifications or other identity documents including your driver’s license, We may also collect additional information from you depending on the nature of the transaction, such as information concerning your business and financial information related to your business and/or you, for example your Social Security Number/Individual Taxpayer Identification Number/National Insurance Number (as applicable depending on your country or state of residence). We also collect your username and password for access to the Site. We collect information from you when you (i) register on the Site, (ii) fill out forms or fields on the Site, (iii) complete an application for a product or service available through the Site , (iv) use the Site or authorize us to access any financial information stored or processed by a third party, or (v) provide us with PII or other information via the Site.
b. Information We Automatically Collect:
Industrious collects certain information about you automatically when you visit the Site, communicate through the Site, or use any of our online Services. We automatically receive certain information from your browser or mobile device, such as your browser type, the operating system of your device, the URL of the site from which you came and the URL of the site you visit when leaving the Site or any of our online Services, the equipment you use to access the Site, the unique identifier of your mobile device and your activities on the Site, such as the webpages you view and how you interact with those webpages. We also receive your IP address and the name of your internet service provider (“ISP”) or your mobile carrier. Depending on your device’s settings, we may also receive location data and other types of information sent from third-party services or GPS-enabled devices.
c. Information Provided by Third Parties:
Industrious also collects PII from sources that you have authorized to share with us or that you have authorized us to obtain information from. These include your financial institution when you make a payment through the Site. We will use your PII in those circumstances to provide the Services that your PII was shared with us to fulfill. If you believe Industrious received your PII from a source without authority to share your PII with us, please contact us so that we can resolve your complaint.
3. How We Use Your Information
Industrious uses PII for the following purposes:
- To improve customer service: Your information helps us to more effectively communicate with you, respond to inquiries, and to respond to your customer service requests and support needs. These may include dealing with any enquiries or issues you have about how we collect, store and use your PII, or any requests made by you for a copy of the information we hold about you.
- To personalize user experience: We use information in the aggregate to understand how our users as a group use the Services and resources provided on the Site.
- To improve the Site: We continually strive to improve our Site and the Services based on the information and feedback we receive from you.
- To send periodic emails: The email address you provide for the Services will only be used to send you information and updates pertaining to the Services requested. It may also be used to respond to your inquiries, and/or other requests or questions submitted via the Site.
- Fulfillment of Obligations: Comply with contractual obligations, relevant industry standards and our policies.
- Security: Mitigate fraud, enhance the security of the Site and manage institutional risk;
- Internal administration: We collect, use and store PII for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.
We may convert PII into Non-Personal Information by excluding information that is personally identifiable. You acknowledge that Non-Personal Information and PII that is converted into Non-Personal Information belongs to Industrious and that Industrious has the right to use such general information as it determines in its sole discretion. Notwithstanding the foregoing, Industrious will treat as PII any item that, either alone or together with other information, we could use to identify an individual. Except as described above, we will not share with third-parties any PII without your permission.
4. Web Browser Cookies
We will use commercially reasonable methods to keep PII securely in our files and systems.
6. Do Not Track
Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, the Site is not programmed to recognize Do Not Track signals, so the Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.
7. Links to Other Sites
8. Age of Consent
Industrious takes special care to protect the privacy needs of children under the age of 13 and we encourage parents to be an active participant in their child’s online activities. Industrious abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The Site does not target and is not intended for children under the age of 13, and Industrious will not knowingly collect Personally Identifiable Information directly from them. If Industrious discovers that a child has provided personal data directly through the Site, Industrious will eliminate that data. This Site is only intended for persons 18 years of age or older. If you are under 18 you must ask a parent or legal guardian for permission prior to submitting any information to this Site. If you have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to us, please contact us and we will delete the PII information collected belonging to that child. You may contact us via email or by writing to us at the address below. Parents and guardians can also email us at firstname.lastname@example.org, but before any information is disclosed, the parent will be required to provide verification of his/her identity and authority related to any request. We will only send the information to the parent email address in the registration file.
9. CAN-SPAM Compliance Notice
Industrious fully complies with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from us.
10. California Privacy Rights
Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship. That information is about the Personally Identifiable Information those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of Personally Identifiable Information shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by Industrious under Section 1798.83 of the California Civil Code, please contact us via email to PrivacyNotifications@industriousoffice.com.
11. CALIFORNIA CONSUMER PRIVACY ACT
Your Rights Under the CCPA:
Under the California Consumer Privacy Act (“CCPA”), California residents are granted the following rights:
- To know what personal information is being collected about them;
- To know whether their personal information is sold or disclosed and to whom;
- To say no to the sale of their personal information;
- To access their personal information;
- To have their personal information deleted; and
- To have the right to equal service and price, even if they exercise their privacy rights under this law.
When receiving a request, we will verify that the individual making the request is the resident to whom the personal information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent to make requests to disclose certain information about the processing of their personal information or to delete personal information on their behalf. If you use an authorized agent to submit a request, we may require that you provide us additional information demonstrating that the agent is acting on your behalf. With respect to their personal information, California residents may exercise the rights described below.
Categories of Personal Information Industrious Collects:
We collect information that identified you, your household or your device or is reasonably capable of being connected with or linked to you, your household or your device. “Personal information” does not include public information available from government records, de-identified or aggregated information or information that is protected by certain laws such as HIPAA for health related information and the Gramm-Leach Bliley Act for certain financial institutions. We collect, process and share some or all of the following categories of personal information:
Categories of Sources of Personal Information
- First and last name
- Postal address
- Telephone number
- Cellular telephone number
- Geographic area
- Internet protocol address
- State driver’s license number
- Social Security Number/Individual Taxpayer Identification Number
- Documents to verify your identity
- Your occupation
- Copies of government identifications
- Commercial information
- Transaction information
- Products or services purchased, obtained or considered
- Your purchasing or consuming history or tendencies
- Financial Information about your company
- Information about your business
- Geolocation data
- Inferences drawn from this personal information to create a profile about you.
Industrious collects information from the following categories of sources:
How We Share Your Personal Information:
- Directly from you. For example, information you provide us directly during a telephone call, filling out an offline form or questionnaire, or providing information online through the Site.
- From third parties.For example, information you provide to your financial institution or information gathered by a financial institution based upon your transactions with Industrious.
Industrious shares information in each of the above categories as follows:
How We Use Your Information:
- We will share information in all of the above categories if our company is sold or we engage in a merger or other such transaction.
- We will share information in all of the above categories of information in connection with a law enforcement request that is compliant with the California Electronic Communications Privacy Act.
- We share identifiers with service providers who use that information only to provide services to us or that we utilize the services of to provide you with products or services, communicating with you, analyzing website use, processing payments and processing data related to the products and services we provide you.
- We share commercial information with data analytics providers.
- Geolocation Information.
- We share internet or other electronic network activity information with data analytics providers.
See above for how Industrious uses your information. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
How We Retain and Store Your Personal Information:
Industrious retains your personal information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protection your information while in storage.
Requests to Know:
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the prior 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- The business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we share your personal information.
- The specific pieces of personal information we have collected about you
- If we sold or disclosed your personal information for a business purpose, which we will not, two separate lists disclosing:
- In the case of a sale, the categories of personal information sold about the consumer and the categories of third parties to whom the personal information was sold, by category of personal information for each category of third parties; and
- In the case of disclosure for a business purpose, the categories of personal information that were sold or disclosed for a business purpose and if personal information has not been sold or disclosed for a business purpose, that we did not do so.
We are not required to (i) retain personal information about a consumer if collected for a single one-time transaction if, in the ordinary course of business, that information would not be retained and (2) re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a way that would be considered personal information. Requests to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies, which we will disclose to you. We are not required to grant your deletion request if retaining the personal information is necessary for us or our service providers to:
How to Submit a Request to Know or a Request to Delete:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impact existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest when the deletion of the public information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- For solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Internally make otherwise lawful uses of your personal information that are compatible with the context in which you provided the personal information.
To request this information, please submit a verifiable consumer request to us by either:
- Email us at email@example.com
- Or by mail at: Industrious, Attn: Privacy Compliance Officer, 215 Park Avenue South, Suite 1100, New York, NY 10003
- Or complete a CCPA Consumer Request Form through your Industrious account.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We are not required to provide you with personal information more than twice in a 12-month period.
Industrious will not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Industrious will try to respond to your request within forty-five (45) days of receipt of your written request. If we require more time (up to 90 days), we will inform you of the extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
An amendment to the CCPA provides an exemption to the Right to Know and Right to Delete for personal information between a business and a person who is acting as an employee, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government where the information is used in the context of a business transaction. This exemption is currently set to expire on January 1, 2022. Until that date, we will not respond to requests to know or delete that are within the scope of this exemption.
How to Submit an Opt-Out Request:
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at:
- Email us at firstname.lastname@example.org
- Or by mail at Industrious, Attn: Privacy Compliance Officer, 215 Park Avenue South, Suite 1100, New York, NY 10003
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sharing with third parties. However, you may change your mind and opt back in to personal information sharing with third parties at any time by emailing us at email@example.com.
We will only use personal information provided in an opt-out request to review and comply with the request. We will act upon your opt-out request within 15 days of receipt.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
12. YOUR NEVADA PRIVACY RIGHTS
Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information should we change our practices in the future, you must send a request by email to firstname.lastname@example.org.
13. PRIVACY INFORMATION FOR EU AND UK RESIDENTS
Industrious National Management Company LLC (“Industrious”) is the controller of your PII, and is responsible for your PII. Please refer to the sections above entitled “Information Collected” and “How We Use Your Information” for information on the categories of PII we hold about you; the sources of such information; and the purposes for which we process it.
A word about cookies.
Legal basis for use of your PII.
b. our use of your PII is necessary for complying with our legal obligations (for example, for health and safety purposes); or
c. where neither (a) nor (b) apply, use of your PII is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
- run, grow and develop our business (as well as the businesses of our group companies)
- operate our Site;
- carry out marketing, market research and business development;
- evaluate and improve our Site and Services provision; and
- for internal group administrative purposes.
If we rely on our (or another person’s) legitimate interests for using your PII, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the PII. You can ask us for information on this balancing test by using the contact details set out further below in this section.
We may process your PII in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below). If we rely on your consent for us to use your PII in a particular way, but you later change your mind, you may withdraw your consent by contacting us at email@example.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide some of our Services to you.
How and why we share your PII with others.
We may share your PII with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
We will share your PII with the following third parties or categories of third parties:
- Our group companies, suppliers and contractors to the extent necessary to fulfil our duties to you and to provide the Services to you;
- Service providers who assist us with business functions including networking, marketing, social, recruitment activities, data analytics (including analysing use of the Site); processing payments;
- Technology or equipment providers;
- Third-party legal counsel; and
- Consultants or auditors.
We will also disclose your PII to third parties:
- where it is in our legitimate interests to do so to run, grow and develop our business:
- if we sell or buy any business or assets, we may disclose your PII to the prospective seller or buyer of such business or assets;
- if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case PII held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your PII in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- to protect the rights, property, or safety of Industrious, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Save as expressly detailed above, we will never share, sell or rent any of your PII to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your PII in a particular way, but later change your mind, you should contact us and we will stop doing so.
International data transfers.
In order to provide you with the Industrious services, we may transfer your personal data to the United States or other countries. These countries’ privacy laws may be different from those in your home country and may not provide the same level of data protection. For example, governmental or regulatory authorities may have wider rights of access to your personal data and you may not be able to seek details or challenge their access or exercise any other right as may apply in your country of origin.
For example, PII may be maintained or accessed in servers or files in the United States of America, which the European Union has not deemed to provide “adequate” privacy protection.
With respect to data transferred by Industrious from the European Economic Area or the United Kingdom, Industrious has in place appropriate safeguards according to applicable data protection law, such as EU Standard Contractual Clauses, to protect the information you provide. Where allowed by applicable law, you may ask for further information on the safeguards that we have put in by contacting us as indicated below.
Industrious is committed not to disclose your personal information in response to a court order or a subpoena or other legal obligation unless it is legally compelled to do so. In particular, Industrious National Management Company has assessed and is of the view that it does not qualify as a provider of electronic communication service, as defined in 18 U.S.C. § 2510, nor a provider of a remote computing service, as defined in 18 U.S.C. § 2711, and thus US public authorities cannot issue a data disclosure demand under the US Foreign Intelligence Surveillance Act (“FISA”) upon CBRE, Inc.
How We Retain and Store Your Personal Information:
Industrious retains your personal information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protection your information while in storage. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Your Privacy Rights.
You have the following rights:
- The right to request access to your data;
- The right to request a copy of your data in a portable format;
- The right to request the correction of data we hold about you;
- The right to request that we erase your data;
- The right to request restriction of the processing of your data;
- The right to object to our processing of your data; and
- Where we process data based on your consent, the right to withdraw that consent at any time.
To exercise any of these rights, please contact us at firstname.lastname@example.org.
You also have the right to file a complaint with the applicable Data Protection Authority. If you are a resident of the United Kingdom, this will be the Information Commissioner’s Office. If you are based in the European Economic Area, a list of Data Protection Authorities is available here from the European Data Protection Board.
- Email us at email@example.com
- Or by mail at: Industrious, Attn: Privacy Compliance Officer, 215 Park Avenue South, Suite 1100, New York, NY 10003