East Room Privacy Policy

1. Introduction

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 East Room. You can read more about how Personal Information is used by clicking below on the name of East Room 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.

2. Information We Collect

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:

• that you provide to us directly.
• that your company, broker, host, parent, or guardian provides to us;
• about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies. For more information about these technologies, please see our Cookie Policy;
• If you opt-in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts;
• from third parties such as our landlords, building managers, licensees and property brokers); and

Information Collected From You:

East Room 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:

• Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;
• Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth;
• Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;
• Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;
• Office Preferences, including your requested or preferred temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences related to the Services.
• Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit an East Room location. These include services such as printer or Wi-fi usage, and desk or conference room bookings;
• Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through feedback platforms, automated chatbots or similar technology, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services;
• Device and Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:
• Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address.
• Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, as further set forth in our Cookie Policy, and your offline activity, including information about events you attend at East Room locations; and

Information Collected About You

• Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest to one of our spaces.
• Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to visiting the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
• “Do Not Track.” If you have enabled the feature, your web browser may transmit “do-not-track” signals to our websites and other online services with which your browser communicates. We currently do not take any action in response to these signals.
• Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, East Room enables you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools transmit Personal Information to East Room to enable you to access your user accounts and to enable East Room to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

3. Use of Personal Information

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

• provide you with our products and Services, including online and offline events, and other materials you request;
• protect against fraud, abuse, or harm and to otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
• respond to or fulfill customer service requests;
• analyze, better tailor, and improve our products and Services;
• contact you about our Services, promotions, and sweepstakes, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you through various means, which may include by email, telephone, post, or by other means as communicated to you from time to time; and
• comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

4. Sharing of Personal Information

We disclose your Personal Information in limited circumstances to East Room, 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:

Among East Room. We may share your Personal Information among East Room businesses or entities depending on where you are located and the Services that you use. East Room uses your information in accordance with this Policy, and we share this information for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services that we provide.

Our Community. Our Services include online and offline member communities, forums, networks, and other features through which you may share information and connect with others. This includes:

• Our Services may make member networks, chat rooms, forums, and/or other groups available to users. Remember that anyone can read, collect, or use your postings on a network or forum or in a chat room or group and we cannot be responsible for any unauthorized third party’s use of information that you publicly disclose online.
• We foster our community by creating profiles for members or permitting members to create their own profiles on member networks or forums. Typically, such a profile contains your name, the name of your company, and other information you provide or add to your profile (content, comments, photos, etc.). Depending on the Services you use, this profile might be created automatically and be accessible to other members of the network or forum. Member Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).
• When we receive information about you in connection with your relationship with our members or clients—for example, if you are a member’s employee or if you are visiting one of our clients—we may share your information with the member or client with which you have such a relationship, for example, by alerting the member or client that you have arrived to visit. Please note that we are not responsible for the privacy practices of our members or clients, or their third-party service providers, including those they integrate with our Services.
• We also may share information about you with others in the community to provide you with certain features.

Primary Members. Information on the utilization of our services by individual members may be shared with the primary member or the organization who purchased the memberships. Examples of individual members are employees of a member company or students of a member university.

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

• Research / Survey Solicitations. From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
• Third-Party Advertising Partners. We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.
• Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Information to other parties:
  • to provide you with the Services that you or your company request;
  • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
  • to comply with applicable law or respond to a legal process or a request for cooperation by a government entity or law enforcement;
  • to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or
  • to protect our rights, property, and safety or that of any of the East Room companies, business partners, members, or employees; and
  • where otherwise required by applicable law.

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.

Other Parties in Connection with a Corporate Transaction. We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.

Other Third-Party Partners, With Your Consent. We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.

4.1 Third Parties That Provide Content or Functionality on Our Services

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

• provide you with our products and Services, including online and offline events, and other materials you request;
• protect against fraud, abuse, or harm and to otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
• respond to or fulfill customer service requests;
• analyze, better tailor, and improve our products and Services;
• contact you about our Services, promotions, and sweepstakes, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you through various means, which may include by email, telephone, post, or by other means as communicated to you from time to time; and
• comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:

• 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 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 offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.

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-East Room 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 website operated by the Digital Advertising Alliance of Canada.

4.2 Social Media

We are active on social media (e.g., Instagram, 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.

5. Rights in Your Information: Access, Rectification, Erasure, and Restriction

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

1. request confirmation of whether we store, use, or share any of your Personal Information and be informed about third parties with whom your Personal Information has been shared;
2. obtain access to or a copy of your Personal Information;
3. receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
4. restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;
5. seek correction of inaccurate, partial, untrue, or incomplete Personal Information; In some cases, we may provide self-service tools that enable you to update your Personal Information;
6. request erasure, anonymization, or blocking of Personal Information held about you by East Room, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
7. withdraw your consent to our processing of your Personal Information. If you refrain from providing Personal Information or withdraw your consent to processing, some features of our Service may not be available;
8. object to an automated decision East Room has made and request the review of decisions taken exclusively based on automated processing if that could affect data subject rights; or
9. cancel your online account if one has been created.

If you would like to exercise any of these rights, please contact us at info@eastroom.com or at one of the physical addresses.

We will process all such requests in accordance with local laws. To protect your privacy, East Room will take steps to verify your identity before granting access or making any changes to your Personal Information.

6. Opt-Our and Withdrawal of Consent

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 East Room’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, East Room will endeavour to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, East Room will comply with the law or contract.

6.2 Email and Telephone Communications

• Opting Out of Marketing Communications. We will provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt-out of those communications, e.g., communications regarding updates to our Terms & Conditions or this Policy. If you no longer desire to be contacted by us, you must terminate your relationship with East Room and can no longer use our Services.
• Collaboration. We do not sell your Personal Information to third parties for their direct marketing purposes. We may partner with other organizations to run events or programs. The Personal Information and other information that you provide to sign up or participate in that event or program will be available to that organization, and you may receive emails or other communications from it after the event. Please refer to that organization’s privacy policy for information on how to opt-out of its communications.
• Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.

7. Complaints and Suprevisory Authority

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 East Room at info@eastroom.com

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.

8. International Transfers

East Room is headquartered in Canda. 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.

9. Retention

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 defences, 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:

• Continue to develop, tailor, upgrade, and improve our Services;
• Maintain business records for analysis and/or audit purposes;
• Comply with record retention requirements under the law;
• Defend or bring any existing or potential legal claims; or
• Address any complaints regarding the Services.

10. Information Security

The security of all Personal Information provided to East Room is important to us. East Room takes reasonable steps endeavouring 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. Other Rights and Important Features

11.1 CCTV

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

East Room’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 Privacy Policy.

11.2 Collecting of Information from Children

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 East Room, 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 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 East Room.

11.5 Questions or Comments

If you have any questions or comments regarding this Policy, please contact us at info@eastroom.com. East Room 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.