SHARED SPACE PRIVACY POLICY

Shared Space Enterprises LLC (“Shared Space”, “Our”, “We” or “Us”) Shared Space respects and values your privacy. We are committed to maintaining and protecting your Personal Information (as defined below) obtained by reason of your relationship with Shared Space in accordance with The United States Federal Privacy Law, including, but not limited to, The Privacy Act of 1974 to the extent they apply to Shared Space.

Shared Space collects only such Personal Information as is required for the purposes of providing services to its users and collects, uses and discloses Personal Information only for those purposes as would be considered reasonable in the circumstances (including to protect from fraud and to comply with legal and governmental requirements). This Privacy Policy (the “Policy”) is designed to explain the types of Personal Information We collect, how it is used, and the steps We take to ensure your Personal Information is handled appropriately.

This Policy applies to Personal Information collected by Shared Space in connection with Our operations and services, which includes Personal Information collected through Our website, sharedspaceapp.com (the “Site”), as well as the services offered by Shared Space (the “Services”). This Policy is incorporated into and forms part of the Terms of Service for the Services.

By using the Site, the Services or otherwise providing Us with your Personal Information, you are accepting the practices described in this Policy, as they may be amended by Us from time to time, and agreeing to Our collection and use of your Personal Information in accordance with this Policy. If you do not agree to the collection, use and disclosure of your Personal Information in this way, please do not use the Site, Our Services or otherwise provide Shared Space with your Personal Information.”

What is Personal Information?

“Personal Information” is information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. “Personal Information” does not include business contact information, with the exception of business email addresses. The types of Personal Information that Shared Space collects are described below.

This Policy does not cover aggregated data from which the identity of an individual cannot be determined. Shared Space reserves the right to use aggregated data in any way it determines appropriate.

Collection and Use of Personal Information

Shared Space collects your Personal Information for the purpose of setting up and maintaining a user account which allows you to access and use Shared Space’s Services. Our use of Personal Information is limited to the purposes described in this Policy. Shared Space does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.

Mandatory Information

Creating a User Account: You will be required to provide the following Personal Information to create a user account on the Site:

• email address;
• password;
• username/alias;

Users will be able to search for other users using username.

Transactional Notifications: We provide notifications for certain activities relating to your use of our Services despite your indicated e-mail preferences, for example we may send you notices of any updates to our Terms of Service or Privacy Policy even if you have opted not to receive general communications from us.

Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you up to date on our products, services and promotions. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication, or by contacting us at adamaz@sharedspaceapp.com

Information Collected Automatically

We also collect certain types of information whenever you interact with Us through the Site, including, but not limited to, the following:

Information We Collect Automatically When You Access and Use the Site: In addition to any Personal Information or other information that you choose to submit or disclose to Us via the Site or the Services, We and Our third party service providers (including analytics providers) may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Site or one of Our advertisements or other content elsewhere online (“Usage Information”). Usage Information may include, among other information, the browser you are using, the URL that referred you to the Site, all of the areas within the Site that you visit, and the time of day. Our systems may also automatically gather information about the search terms you use on the Site and the links you select from within the Site to other areas of the Web or elsewhere online. In addition, We may collect your IP address or other unique identifier for your computer, cell phone, or other device used to access the Site (collectively referred to as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your computer, your cell phone, or other device used to access the Site, and Our computers identify your device by its Device Identifier. Usage Information may be non-identifying or may be associated with you. Whenever We associate Usage Information or a Device Identifier with you, as an individual and identifiable person, We will treat it as Personal Information.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Site currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

IP Information: In general, We collect and use information and data regarding your access and use of the Site and the Services. When you use a web browser to visit the Site or use the Services, We record the information that your browser automatically sends whenever visiting or using any of the Services, including your web request, the Internet Protocol (“IP”) address and browser configuration of your Device (as defined below), the date and time of your request and the uniform resource locator of the referring and/or exiting websites. In this Privacy Policy, “Device” means a computer, mobile phone, handset, tablet or other device enabled for internet access and/or communication.

Social Media/Integration With Third party Platforms: The Site may permit you to interact with a third party website or service, such as enabling you to “like” Us on another website or “share” content from the Site with other websites (a “Social Networking Service”). If you choose to “like” or “share” content or to otherwise post information from or via the Site to a Social Networking Service, that information may be publicly displayed, and the third party may have access to certain information about you and your use of the Site. Similarly, if you interact with Us through a Social Networking Service, We may have access to information about you (for example, if you “like” or “follow” Our page on a third party website).  Please note that if you mention or comment upon Shared Space or the Site in your post to a third party platform, the third party platform may allow Us to publish your post on the Site.

You may also choose to use a social media tool offered by a third party, but available on the Site (such as posting a review or logging into the Site with your username and password for another website, such as Facebook or Google+). Use of such a feature may allow Us to collect (or the third party to share) information about you, including Personal Information. Information about you, including your name and profile photo, may be shown to other users of the Site if you are logged in through the Site or through a third party website or service or if you have previously posted content to the Site while logged in. When you choose to use a social media tool available through the Site, you may be opting to link your activity on the Site with that third party website or service, which may then collect information about your visits to the Site and may publish that activity as you request to your profile or similar feature with that third party.  For example, when you link your Facebook account to the Site as a means for registering for the Site, some of your Facebook information will be shared unless you disable that sharing.

In addition, We may receive information about you if other users of a third party website give Us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third party website or interactive service.

Cookies and Similar Technologies: The Site may include the following tracking technologies, and similar technologies, and which may be set and controlled by Us or by Our third party service, advertising or content providers (including advertising services such as Google):

Cookies: Shared Space uses cookies, which are small data files that are saved to your Device when you visit the Site and use the Services. Shared Space may use both “session” cookies and “persistent” cookies. A session cookie is only active while you are on the Site and is deleted once you close your browser. Unlike a session cookie, a persistent cookie is not deleted when you close your browser and will stay on your Device indefinitely. Shared Space uses cookies to identify when you return to the Site, save login information (but never passwords), track usage statistics and store your preferences. By default, most browsers will automatically accept cookies, but by altering your browser’s settings, you can either disable cookies completely or be prompted prior to a cookie being loaded. Consult each individual browser’s “help” feature for more information.

Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links on which you click. The code is temporarily downloaded onto your computer, mobile device or other device from Our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

In addition, We may use a variety of other technologies on the Site that collect information for security purposes.

Analytics: Portions of the Site and Services may also use analytical tools (collectively, “Analytical Tools”) that are operated by Us and third party providers, which may use cookies, web beacons, scripts and similar means for the purpose of collecting information and analyzing how you use the Site and Our Services. Information collected using Analytical Tools will be transmitted and stored on servers located specifically in the United States or any other country with which Shared Space, its Affiliates or service providers maintain facilities, and may be accessible to law enforcement or other authorities in those foreign jurisdictions. The third party providers of Analytical Tools may also transfer this information to other third parties (such as governmental authorities) where they are required to do so by law, or where such third parties process the information on their behalf. As some Analytical Tools rely on cookies to perform their functions, you can avoid having your usage data collected by those Analytical Tools by disabling cookies in your browser.

Optional Information

You may wish to voluntarily provide Us with the following information:

• a picture in order to personalize your Shared Space profile;
• company name to facilitate other users to search for you by the company you represent; and/or
• a secret question and secret answer to enable you to reset your Shared Space account password in the future.

To help Us analyze Our user base and improve Our services, you may choose to provide Us with additional information, such as:

Your telephone, email and social network contacts: You may also choose to provide Us with the following information, which We will use to help you connect with other Shared Space users in your contacts and social networks. However, this information will not be retained:

• Your phone contacts;
• Your email contacts;
• Your social network contacts; and
• Your social network login credentials.

Communications: When you send email or other communications to Us, We may retain those communications in order to process your inquiries, respond to your requests and improve the Services.

Consent to Collection, Use and Disclosure of Personal Information

Consent to collect, use and disclose personal Information may be “express”, or may be “implied”, for example, when you provide information necessary to use one of Our services. By accessing or using Shared Space you agree and consent that We may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific, express authorizations or consents may be obtained from time to time.

Withdrawing Consent to the Collection, Use and Disclosure of Personal Information

You are free to withdraw your consent to Our collection, use and disclosure of your Personal Information at any time, subject to contractual and legal restrictions and reasonable, advance notice. If you have given Us contact information and no longer wish to be contacted, contact Us by email and We will remove it from Our system. However, it should be noted that if you withdraw your consent to certain uses of your Personal Information, We may no longer be able to provide you with certain Services or you may not be able to take advantage of all of the features and functionality of the Services.

Managing Your Information Preferences

You can review, correct, update, change, and delete your Personal Information by changing the relevant settings in your user account.

Privacy Profile Settings: There are three levels of privacy settings, applicable each time a user posts content:

1. private (profile can only be viewed by user);
2. connections (specific users can be grouped into this category); and
3. public (accessible by Shared Space network).

Who May Have Access to Your Personal Information?

Users will be able to search for other users using first name, last name, or email address. In addition, users will be able to search for other users by username or company name, if that information has been voluntarily provided.

Shared Space does not disclose any of your Personal Information without your informed consent, unless We are required or permitted to by law (including in order to comply with a court order, federal or provincial regulations, or a legally permitted inquiry by a government agency) or as described in this Policy. Where obligated or permitted to disclose information without consent, Shared Space will not disclose more information than required.

We maintain strict controls over access to the Personal Information you share with Shared Space. Within Shared Space, access to your Personal Information is granted only to authorized employees and agents of Shared Space who require access to fulfill their job requirements, or on a “need to know” basis.

Your Personal Information may be shared in the following ways:

• We may share Personal Information internally to improve Our services;
• We may de-identify your Personal Information and share anonymized data with third parties;
• We may combine your information with other information in a way that it no longer identifies you and share that aggregated information internally or externally with third parties for the purpose of enhancing the services We offer and your user experience;
• We may access, preserve and share your information internally or with law enforcement officials in response to a legal request if We have a good reason to believe that the law requires Us to do so.

Except as set out in this Privacy Policy, Shared Space does not sell, trade, or otherwise transfer to outside parties your Personal Information. We may transfer your Personal Information to trusted third party service providers who assist Us in administering and providing the Site or the Services. If your Personal Information is shared with third parties, those third parties will be bound by appropriate agreements with Shared Space to secure and protect the confidentiality of your Personal Information.

Information, including Personal Information, which We collect from users of the Services and others, is considered to be a business asset. As a result, in the unlikely event that We go out of business, enter bankruptcy or if We are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third party acquirer in connection with the transaction.

You are deemed to consent to disclosure of your Personal Information for those purposes. If your Personal Information is shared with third parties, those third parties are bound by appropriate agreements with Shared Space to secure and protect the confidentiality of your Personal Information.

We may disclose your Personal Information when We believe such disclosure is appropriate to comply with the law, enforce Our policies, or protect Our or others’ rights, property or for safety.

Protection of Personal Information

Shared Space recognizes the sensitivity of your Personal Information and protects it using appropriate physical, electronic or procedural security measures with respect to its offices and information storage facilities. This may include safeguards to protect against loss or theft, unauthorized access, disclosure, copying, use or modification. This also applies to Our disposal or destruction of Personal Information.

Only authorized employees, contractors and agents of Shared Space, who require access to your Personal Information to fulfill their job requirements, will have access to your Personal Information. All Personal Information files and data are the sole property of Shared Space.

Transfer or Storage Outside United States

Information may be securely transferred or stored outside of the United States, or to any other country in which Shared Space, its Affiliates or service providers maintain facilities. Where information is transferred or stored outside the United States, it may be accessible to foreign law enforcement and other foreign authorities.

Accuracy and Retention of Personal Information

Shared Space endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which We use that information. If We become aware that Personal Information is inaccurate, incomplete or out of date, We will revise the Personal Information.

We keep your Personal Information only as long as it is required for the reasons it was collected.  The length of time We retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with Us, but it will be only for so long as it is necessary for Us to have sufficient information to respond to any issues that may arise at a later date.

When your Personal Information is no longer required for Shared Space’s purposes, We have procedures to destroy, delete, erase or convert it into an anonymous form.

If you would like to access or correct Shared Space’s file of your Personal Information, you may contact Customer Service at adamaz@sharedspaceapp.com Your right to access or correct your Personal Information is subject to applicable legal restrictions.

PRINCIPLES

Shared Space’s employees, agents and subcontractors with access to your Personal Information are expected to have basic knowledge and understanding of the general principles underlying “Privacy Act of 1974” and substantially similar provincial legislation:

1. Accountability

An organization is responsible for Personal Information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.

2. Identifying Purposes

The purposes for which Personal Information is collected shall be identified by the organization at or before the time the information is collected.

3. Consent

The knowledge and consent of an individual are required for the collection, use, or disclosure of Personal Information, except where appropriate.

4. Limiting Collection

The collection of Personal Information shall be limited to that which is necessary for the purposes identified by the organization.  Information shall be collected by fair and lawful means.

5. Limiting Use, Disclosure and Retention

Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.  Personal Information shall be retained only as long as necessary for the fulfilment of those purposes.

6. Accuracy

Personal Information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is used.

7. Safeguards

Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.

8. Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.

9. Individual Access

Upon request, an individual shall be informed of the existence, use, and disclose of his or her Personal Information, and shall be given access to that information.  An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designate individuals accountable for the organization’s compliance.

Interactions with Third Parties

This Policy only addresses the use and disclosure of information collected from the use of the Site and Services. We make no representations or warranties about the privacy practices of any third party individual, website or service that you may encounter through the use of the Site and Services. As third party individuals, websites and services are wholly independent from Shared Space, We are not responsible for the privacy practices of third parties or the content of any third party websites that may be linked by Shared Space or other Shared Space users. Therefore, user transactions with any third parties and access to any third party websites or services is entirely at your own risk. It is also your responsibility to take all protective measures to guard against viruses or other destructive devices and programs. You should refer to the privacy policies of third parties if you have any questions.

Resolving your Privacy Concerns

In the event of questions about: (i) access to your Personal Information;  (ii) Our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact Shared Space by sending an e-mail to adamaz@sharedspaceapp.com

Shared Space will investigate all complaints and if a complaint is justified, We will take all reasonable steps to resolve the issue.

If We are unable to resolve your concerns to your satisfaction you may contact Privacy at the Department of State by visiting: https://www.state.gov/privacy/

Privacy Policy Changes

This Policy may be revised from time to time. If We intend to use or disclose Personal Information for purposes not described in this Policy, We will make reasonable efforts to notify affected individuals in advance, if necessary. If you are concerned about how your Personal Information is used, you should contact Us as described above or check back at Our Site periodically to obtain a current copy of this Policy.

This version of this Privacy Policy is effective as of April 23rd, 2018.