TAG CoWorking Privacy and Data Protection Policy and Notice Last Updated: December 20th, 2019
TAG CoWorking (including its wholly and partially owned subsidiaries) ("TAG", "we", "our" or the "Company", and their cognates) respects the privacy of its customers, employees, candidates, members and followers, and is committed to protecting the personal information that its Users share with it. We are transparent about our practices regarding the information we may collect and use when you use the Services, apply for a position, are employed by us, visit our office sites, visit our websites or otherwise engage with us, and describe our practices in this policy and notice.
TAG provides open work spaces, private offices and related office services at its facility locations (the "Services"). A User may be either an entity, for example an employer which has executed an agreement with TAG ("Customer ") or a Customer's users, for example a Customer's employees, of the Services ("End User(s)") (Customer and End User and any others with respect to whom we collect personal data, shall collectively be referred to as "Users" or "you" or "Data Subjects").
Please read the following carefully to understand our practices regarding your personal data and how we will treat it. For the purposes of European Economic Area data protection law, (the "Data Protection Law"), TAG will usually be a data controller (the "Controller").
WHICH INFORMATION MAY WE COLLECT? Categories of information and data we may collect from our Users. Data we collect about you from your use of the Service One type of Data is non-identifiable and anonymous information ("Non-personal Information"). We also collects several categories of personal data ("Personal Data"). Personal Data which is being gathered consists of any details which are personally identifiable provided consciously and voluntarily by a Customer, End User or the Customer's administrator or through your use of the TAG application and website (as described below). This may include your name (first and last), email address, phone numbers, picture, postal address, birthdate, gender, position and organization name, your bank account, credit card and other such payment and billing details, billing address, your social security for the background check, your TAG application account username and password and usage details, and other information User may choose to provide to TAG. Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the TAG website or application is used. If you are visiting a User at one of our facility locations, we may ask you for your name, email address, phone number and the name and position of the person you are visiting. We use this information to facilitate our legitimate interest of providing reception services to Users and in order to let the User know that you are on your way to them, as well as to ensure the safety and security of our Users and premises. You do not have any legal obligation to provide any information to TAG however, we require certain information in order to provide the Services. If you choose not to provide us with certain information we may not be able to provide you with some or all of the Services. TAG may also collect the email addresses of people who communicate with TAG via email or via messenger services or other social media platform or create accounts and login credentials. By registering on TAG's general website, TAG will collect your name, company name, phone number and company email you provided. TAG may use this information to offer TAG's services and support. TAG also collects Personal Data through the use of CCTV cameras and members' site access cards. This may consist of video images of you in the public spaces at TAG offices, as well as records of your entrances and exits of the TAG buildings and office floors. TAG may not be aware of the nature of the information collected through the Services (for example, through CCTV), and such information may include sensitive or special categories of Personal Data, but we do not knowingly collect such data about our Users, members, site visitors etc ("Sensitive Information"). TAG also collects data relating to employees. This is governed by a specific notice we have made available to our employees. TAG also collects data relating to employment candidates. This includes CVs and the data contained therein, notes on meetings, standardized tests, reports, references, interviewer impressions and such industry standard data, as well as collecting data made publicly available or available to us on social networks. We collect such data based on the intention of the candidate to enter into an employment agreement with TAG.
WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT? We will use Personal Data to provide and improve the Services and meet our contractual, ethical and legal obligations, including for example:
carrying out our obligations arising from any contracts entered into between you and TAG and/or any contracts entered into between a Customer and TAG and to provide you with the information, products and Services that you request from TAG; administering your account with TAG including to identify and authenticate your access to the parts of the Services that you are authorized to access. verifying and carry out financial transactions in relation to payments you make in connection with the Service; notifying you about changes to our Service; contacting you for the purpose of providing you with technical assistance and other related information about the Service; replying to your queries, troubleshooting problems, detect and protect against error, fraud or other criminal activity; contacting you to give you information about events or promotions or additional Services offered by TAG, including in other locations; soliciting feedback in connection with your use of the Services; tracking use of TAG facilities and services to enable us to optimize and improve our services; contacting you to inform you of additional services and locations which may be of interest to you; compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, members, facilities etc; for security purposes and to identify and authenticate your access to the parts of the Services and our application that you are authorized to access.
Personal Data which you provide us may be combined with personal data which your employer, a TAG customer, provides us, or which may be provided by other sources, all of which will be used for for the purposes set out above. 4. SHARING DATA WITH THIRD PARTIES We may transfer Personal Data to: Members of TAG: This includes any member of TAG, which means our subsidiaries – whether wholly or partially owned by TAG, in the US and elsewhere, who support our processing of personal data under this policy. Third Parties. We transfer personal data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website, our application, and our marketing. Some customers of TAG require for their data security and management to know the identity of anyone who accesses their office space, for example, the identity of vendors (such as delivery services, catering, IT support, contractors, cleaning etc) and their staff who are on site. For customers of ours who reasonably require it, we will transfer the names of any of staff, visitors, vendors, etc who have access to their office space. We periodically add and remove third party providers. At present our third party providers to whom we may transfer personal data include also the following:
Google analytics, General statistics, https://policies.google.com/privacy?hl=en Mailchimp, email marketing https://mailchimp.com/ Nexudus, coworking management http://nexudus.com/ Quickbooks, financial information https://quickbooks.intuit.com/ Cloudfare, site optimization https://www.cloudflare.com/ Instagram, social media pictures http://instagram.com/ Facebook, social media pictures https://www.facebook.com/ SnapWidget, social media pictures http://snapwidget.com/ Twitter, social media http://twitter.com/ Our lawyers, accountants, local payroll service providers, other standard business service providers.
To the United States of America. Transfer to the US is done subject to the Privacy Shield program; where that is not available, we will make such transfers subject to Standard Contractual Clauses; and Within the EU.
We may transfer your personal data outside of the EEA, in order to:
Store or backup the information; Enable us to provide you with the Services and fulfill our contract with you; Fulfill any legal, audit or compliance obligations which require us to make that transfer; Facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights; To serve our customers across multiple jurisdictions; and To operate parent company, subsidiaries and affiliates in an efficient and optimal manner.
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