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Privacy policy

Office @Highland Global Privacy Policy

Effective Date: June 1, 2020

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

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

References to “you.” In this Policy, “you” means anyone who uses our websites, applications, or other Services. If you are an employee or applicant, the Office @Highland Privacy Policy explains how we use Personal Information in the context of our employment relationship with you. If you are an employee or applicant that uses our Services, this Policy explains how we collect, use, and disclose your Personal Information in the context of your use of our 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:

INFORMATION COLLECTED FROM YOU Office @Highland 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:

This includes:

o Device identifiers, such as IP address, WiFi MAC address, and Bluetooth address. Click here for more information about choices to opt out of the use of Mobile Location Analytics to capture your mobile device’s WiFi MAC address or Bluetooth address;

o Geolocation information, such as through your mobile device’s GPS signal or WiFi signal, and information about your contacts, depending on your device settings;

o 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; and

o Space utilization information and information about how you use our Services, including through Spatial and People Analytics Sensors (“SPA Sensors”) in offices, kitchens, conference rooms, and other spaces of some facilities that you may work in or visit, to promote more efficient and comfortable uses of the Services. Examples of SPA Sensors include desk occupancy sensors, environmental sensors, WiFi network hubs, and optical camera-powered sensors.

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.

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:

LEGAL BASES FOR PROCESSING END USER PERSONAL INFORMATION 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 a Secure Environment, and analyzing, improving, and better tailoring our products and Services.

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.

4. SHARING OF PERSONAL INFORMATION We disclose your Personal Information in limited circumstances to Office @Highland, our community, our service providers and advertisers, and other end users, in order to provide our Services and to improve ways of working in our community. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.

o 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.

o 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. Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).

o 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.

o We also may share information about you with others in the community to provide you with certain features. For example, if you sign up for a mentoring program, we may share information about you with potential mentors.

Personal Information to other parties:

o to provide you with the Services that you or your company request;

o to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;

o to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;

o to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or

o to protect our rights, property, and safety or that of any of the Office @Highland family of companies, business partners, members, or employees; and

o where otherwise required by 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.

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:

4.2 SOCIAL MEDIA We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and video 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 (i) request confirmation of whether we store, use, or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information or, as described above, object to those uses; (v) seek correction of inaccurate, untrue, or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by Office @Highland, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at office@athighland.com or one of the physical addresses set out in Section 12.5 below.

We will process such requests in accordance with local laws. To protect your privacy, The Company 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.

6. OPT-OUT You have the right to opt-out of certain uses and disclosures of your Personal Information as set out in this Policy, and in specific circumstances, for example related to direct marketing.

6.1 GENERAL Where you have consented to Office @Highland 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 Data for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Office @Highland 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 Company will comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE Should the Company engage in interest-based advertising, it will endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service, The Company’s online advertisements may sometimes be delivered with icons that help individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit http://www.aboutads.info/choices/.

7. SUPERVISORY AUTHORITY For visitors to our Services in the EU, you may lodge a complaint with a supervisory authority if you believe our processing of your Personal Information infringes applicable law.

8. INTERNATIONAL TRANSFERS Office @Highland 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 data protection 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 below in Section 12.5.

9. RETENTION Office @Highland will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended.

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

10. INFORMATION SECURITY The security of all Personal Information provided to Office @Highland is important to us. The Company 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. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while the Company strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to the Company, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials or badge with others, logging out when you leave your desk, and other security best practices.

11. AUTOMATED PROCESSING In the future, we may use automated processes to help us determine your eligibility for new services, alternate space, or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, or request that we restrict the use of your Personal Information for the purposes of these automated decisions.

12. OTHER RIGHTS AND IMPORTANT INFORMATION

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

12.2 COLLECTION OF INFORMATION FROM CHILDREN Generally, our online 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 under has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.

12.3 THIRD PARTIES This Privacy Policy does not apply to services not provided by Office @Highland. 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-party websites.

12.4 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 “Effective Date” below to indicate when those changes will become 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 Office @Highland.

12.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding our Policy, please contact us at office@athighland.com.

Privacy Office @Highland 1 Smart Way, Baton Rouge, Louisiana 70810

Office @Highland 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.

Effective Date: June 1, 2020

13. JURISDICTION-SPECIFIC INFORMATION

California Privacy Rights 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. We do not share Personal Information with third parties for their direct marketing purposes. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.

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 office@athighland.com. 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 tried to explain our privacy practices in full 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

Identifiers, such as your name, mailing address, phone number, email address, or IP address We may use this information to respond to your questions, to enable you to participate in our programs (including promotions or sweepstakes), to provide you with online and offline events, to provide our Services, and for other business purposes.

Professional and employment-related information, such as your company name, title, role, or team We may use this information to provide you with the products and Services you request, and for other business purposes.

Commercial information, such as a record of your purchases We may use your information to provide you with the Services you have purchased, to identity other products and offers that may be relevant to you, and for other business purposes

Internet and electronic network activity information, such as information about your interactions with our Services We may use this information to improve our Services, to better understand the visitors who come to our Services and what content is of interest to them, and for other business purposes.

Precise geographic location information, using technologies such as GPS or WiFi We may use this information to improve the quality, security, and relevance of our Services to our visitors, and for other business purposes.

Other electronic or visual information, including information that you share using the Services (such as videos or photos) or footage captured by CCTV We may use this information for our business purposes. For example, we use videos or photos that you share to provide the services you ask for on our Services, as part of sweepstakes or other competitions; and we use footage captured by CCTV to provide a Secure Environment.

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 these categories of personal information within the Office @Highland family of 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. We do not sell your information to third parties for purposes of California law.

Information about how you may exercise your rights as a California resident can be found by calling 225-535-4647 or by contacting Office @Highland at the email or address listed above in Section 12.5, “Questions or Comments.” 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.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

Membership Information. One year from termination of membership, provided, however, this period may be extended if we notify you of the purpose of the extension, the length of the extension period, and the nature of Personal Information to be retained during such period and if you agree to such extension.

Record of cancellation of contracts or subscription. Five years from termination of membership.

Record of payments and supply of goods. Five years from termination of membership.

Record of customer complaints or dispute settlements. Three years from termination of membership.

When Personal Information is no longer required due to the expiration of the Personal Information holding period, or the purpose for which the Personal Information has been obtained has been achieved, we will destroy the Personal Information in accordance with our retention policy. If applicable laws require us to continue to store this Personal Information, we will transfer such information to a separate database or place in a separate storage compartment.