Peerspace Privacy Policy and CCPA Policy

Effective Date: June 8, 2021

I. Introduction

This Privacy Policy explains how Peerspace, Inc. ("Peerspace" or "we") collects, uses, and shares personal information. As used in this Privacy Policy, "you" refers to a user of Peerspace's products or services, including using our website or app ("Services"). Please note, our Services are not intended for children under the age of majority in your jurisdiction of residence. If you are under the age of majority in your jurisdiction of residence, do not use or provide any personal information on or through the Services or about yourself to us. If you believe that we might have personal information from or about a child under the age of majority, please contact us.

II. Collection of User Information

We collect and process your personal information in order to provide you an optimal experience possible when you interact with us. The following chart describes the type of information we collect, the source of that information, our purposes for using the information, and the third parties with whom we may share the information.

Classification of DataCategories of DataSource of Collection
User Data : Data we collect about the individuals who use our services. We associate this data with a unique ID (Host ID or Guest ID) depending on the type of user.Name, email address, zip code, phone number (including country code), city, government ID, title, affiliated organizations such as professional or employment-related information, uploaded photos, social media handles, website URL's affiliated with the user, communications to and from users (including email and chat feature communications), identity verification information, which may include Social Security Numbers (SSNs) , or Social Insurance Numbers (SINs).Provided by you (Users) and third parties.
Identity verification information: Information collected that can help us verify that users are who they claim to be.We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses as well as information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including for fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.Provided by you (Users) and third parties.
Device and Location Data : Data we collect about the device you are usingInternet and associated network information, browser type, device type, method of sign-on, device ID information, IP address.Devices.
Platform Activity Data : Information we collect about how you interact with the Peerspace PlatformAccess date/time, pages viewed, searches made, messages sent, inquiries made, requests made, bookings made, reviews written, boards created, analytics data, error logs.Users and devices.
Cookies and Similar Data : Peerspace's website uses cookies, pixels, and other technologies to make the website work properly and to provide the most relevant services to our site visitors.Cookies send information back to the originating website on each subsequent visit, or to another website that recognizes that cookie, to develop a record of the user's online activity.Peerspace and third parties.
Information about Spaces : Information associated with the spaces listed on our service, which may be associated with a particular individual but typically is associated with a business. We assign a Space ID to unique spaces as well as a Listing ID to unique listings.Address (street address, city, state, province, zip, postal code, country, metropolitan area), latitude and longitude of space, time zone, venue capacity, onsite contact information, space entry instructions, Wi-Fi access instructions.Users and third parties.
Booking Information : Information related to a particular Booking. We assign Booking IDs to each unique Booking.Start/End date, start/end time, Booking details (services descriptions, event description, attendee count, prices, taxes, fees), communications regarding Booking.Users.
Vendor Information : Information we collect about vendors who provide services via our Services.Vendor email, services description, locations, contact information, website, survey responses, vendor questionnaire responses.Vendors.
Survey/Feedback Information : We collect information when you fill out a form, provide feedback, or otherwise communicate with us.Survey question responses, feedback, email correspondence.Users.
Contract Information : We collect information related to the agreements signed between users.Contracts signed, signatures (including electronic signatures), affiliate information, contract terms and other information.Users, vendors, and third parties.
Sensory Information: Audio data, such as a recording of your voice when you contact us via SupportYour voice, recordings of support phone calls, calls connecting you with other usersUsers
Payment Data : We collect information about the means by which you submit or receive payment through our platformCredit card information, bank account information.Users and third parties.
Other Data : We collect additional information from individuals depending on how they use our Services.Calendar information (if access is provided), Space Wi-Fi information, miscellaneous communication information, information related to Events, Bookings, Spaces, or Users (including guest lists, diet restrictions, physical restrictions, or other information).Users, vendors and third parties.
User Interaction/Dispute Resolution : We collect information related to the interactions between our users and other users or third parties. Sometimes this is to facilitate communications between individuals, to resolve disputes, or for other business purposes compatible with the reason for collection.Information provided in relation to our business purposes.Users, vendors, and third parties.
Background Check Information : We may conduct background checks on various individuals as part of our efforts to ensure the safety and security of users on the site.Information related to background checks.Background check service providers.

III. Our Operational and Commercial Purposes

As part of Service offerings we undertake a multitude of operations which require the processing of personal information. For example, our business purposes include: (1) accepting, coordinating, managing, and processing Listings and Bookings; (2) facilitating purchase transactions for goods and services; (3) providing top-level customer support, accommodations, and personalized services and amenities; (4) engaging in quality control in order to improve our offerings to you; (5) facilitating communications between parties; (6) engage in content based or interest-based advertising, (7) ensuring the safety and security of our users, our staff, and all other persons visiting our platform or the properties listed on it, including verifying your identity; (8) prevent, detect, and investigate fraud, cyber incidents, or other illegal activity; (9) communicating with you and others in relation to your use of our services, including providing legal updates; (10) administering our record-keeping for legal, tax, and operational purposes; (11) exploring new and unique ways to provide products and services; and (12) doing our best to fulfill your requests. Our commercial purposes are to advance our commercial interests, including for advertising and marketing. To learn more about how your personal information is processed for marketing and advertising, please see Your Marketing and Ad Choices below.

IV. Disclosures of Your Personal Information

In order to provide you our service and to fulfill our business and commercial purposes, we may disclose your personal information outlined in Section II. Information disclosed to facilitate bookings and other interactions between customers, and to enable your use of the Peerspace platform may include demographic information; financial information; government identifiers; protected classification characteristics; transaction history; internet, application, and network activity; location data; sensory (audio data); professional or employment-related information; and inferences about you.

  1. Publicly Posted Information. Some user information is posted publicly on the platform and is visible by others. This may include profile information, information related to a Space or Listing, reviews, ratings and other feedback, reviews of Guests completing Bookings, and other information that a user submits to be posted. Precise location information is not publicly posted.
  2. Sharing Between Users. Our Services are designed to connect users and to facilitate interaction between them. We also will disclose your personal information to any agents or third parties to whom you authorize us to disclose it, including the operators, managers, agents, or other parties associated with an Event or when you agree to a Booking. This sharing is necessary to ensure the performance of the contract between you and Peerspace, and/or you and a third party.
  3. Our Service Providers : We may share your information to our trusted third party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, dispute resolution providers, advertising providers, governmental entities, social networks, background verification providers and other users. When appropriate or required by applicable law, we will put in place appropriate contracts containing standard data protection clauses to protect that information and the rights of individuals.
  4. Other Disclosures. In addition to the foregoing, we may disclose personal information in the following circumstances: (1) In order to comply with an applicable federal, state, provincial, territorial, or local law; (2) In order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) To cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, provincial, territorial or local law; (4) To exercise and defend legal or payment related claims; (5) When such disclosure is pursuant necessary to protect the rights and freedoms of other individuals; (6) As part of a prospective or completed merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Peerspace, Inc., and (7) In any other manner permitted by law, including engaging in protected speech.
  5. Third Party Links : Links to web sites that are not operated by or for us ("Third Party Sites") are provided solely as a convenience to you. If you use these links, you will leave our website. This Privacy Policy does not apply to Third Party Sites. We have not reviewed the Third Party Sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.
  6. Building Management and Owners: We may disclose personal information of Hosts and Guests such as booking information, and information related to compliance with applicable laws and property management agreements with landlords, management companies, and/or property owners to facilitate the Host Services. For example, Guest Booking and personal information, including Guest contact information, may be shared with the owner/management, staff, reception, or caretaker of the building, complex, or community where a Host lives and/or the listing is located, to facilitate Host Services, compliance with applicable laws, security, billing, and other services.

In addition to the disclosures described above we may also disclose your personal information with your consent for purposes described at the time we obtain your consent.

V. Security

We are committed to protecting the security of any personal information you provide. We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

All financial information you provide, such as credit card data, will generally be transferred over a Secured Socket Layer (SSL) connection (provided that it is supported or enabled on your browser). In spite of these protections, any information submitted over the Internet could be intercepted or otherwise corrupted during transmission, and we cannot guarantee the complete security of any data submitted over the Internet. Sensitive personal information is stored on servers or locations protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. The servers are under our control at all times but may be hosted, managed or otherwise maintained by third party service providers with whom we contract. These third party service providers have no right to use or access this data other than in performing their services for us.

You may access and change certain information that you submitted during registration (if you have registered at the Site) at any time by providing your username and password. Please keep your password in a safe place and do not provide this information to anyone. We strongly encourage you to check the accuracy of your data regularly as we will use your e-mail, phone number, and home address to communicate with you regarding products or services that you have requested. We will not be liable for any problems or difficulties that arise as a result of your failure to keep your information up to date.

VI. International Data Transfers

For users located outside the jurisdiction of the United States, Peerspace, Inc. is located in the United States. Information we collect from you will be processed in the United States and potentially in other jurisdictions, and laws in the United States and other jurisdictions may differ from the laws where you reside. By using our Services (including our website) you acknowledge and consent to the processing of your data in the United States and elsewhere. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate. For information about the manner in which we or our service providers treat Personal Information, please contact us as set out in the "Contact Information" section of the Privacy Policy.

While we do not target individuals in the EU or other jurisdictions outside of the United States, we are aware that individuals from outside the US may interact with us and inquire about the adequacy of our data protection. The United States has not sought nor received a finding of "adequacy" from the European Union under Article 41 of the GDPR. We collect and transfer to the U.S. personal data only with your consent (as provided herein); to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.

VII. Your Marketing and Ad Choices

Like most businesses, Peerspace advertises and markets its Services in various ways. We may use cookies and related technologies to recognize you and receive information about your activity on our websites. This helps customize content and show you more relevant ads. You may limit or disable third party personalized advertising in a number of ways.

Opt-Out of Third-Party Personalized Advertising

You may opt out of cross-site third party personalized advertising using several industry-provided frameworks that many advertisers and advertising networks, exchanges, platforms, and technology providers participate in:

FrameworkList of ParticipantsDirect Link to Opt-Out
Network Advertising Initiative (NAI)https://www.networkadvertising.org/participating-networks/NAI Opt-Out Link
Digital Advertising Alliance (DAA)https://youradchoices.com/aboutDAA Opt-Out Link
Digital Advertising Alliance of Canada (DAAC)https://youradchoices.ca/en/participating-companiesDAAC Opt-Out Link
Digitrusthttps://www.digitru.st/participating-companies/Digitrust Opt-Out Link

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.

Adjust Your Browser Setting to Block Third Party Cookies

You can also use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers is contained here:

To successfully opt out, you must have cookies enabled in your web browser (see your browser's instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser's saved cookies, you will need to opt-out again.

Set Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser's do-not-track request. We cannot control third parties' responses to do-not-track signals or other such mechanisms. Third parties' use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

Adjust Other Settings

You can adjust the information that other third parties collect about you:

  • Using Google's privacy controls to opt-out of ads and cookies set by Google. Please go here and here to opt-out of any personalized ads and cookies.
  • Using Facebook's privacy setting to restrict Facebook's use of cookies. Please go here to do so.

VIII. Information for Canadian Users

Access

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

IX. Children's Privacy

We are committed to complying with the Children's Online Privacy Protection Act (COPPA). Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly destroy such information. Parents are encouraged to supervise their children's online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association's home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

X. Agreement and Changes

By submitting your personal information through our website, you agree to the collection and use of your personal information on the basis described above. If you do not agree, please do not provide any personal information via our website. If we decide to update our Privacy Policy, we will indicate this next to the Privacy Policy link on the front page of our Site. If there are material changes to the Privacy Policy, we will prominently post and/or communicate such changes prior to implementing them. Information collected under previous versions of our Privacy Policy will then become subject to the terms of our new Privacy Policy.

XI. California Privacy Rights

If you reside in California, you have specific rights regarding your personal information. Please see our California Consumer Privacy Policy.

XII. Contact Information

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us by e-mail at [email protected]. Please note, we do not accept consumer rights requests via email.

If you have any questions or comments regarding our privacy practices, or about the manner in which we or our service providers treat your personal information, please contact Rony Chammas (Chief Product Officer) at [email protected].

     

CALIFORNIA CONSUMER PRIVACY POLICY

Effective Date: January 1, 2020

The purpose of this California Consumer Privacy Policy (as updated from time-to-time, this "CA Privacy Policy") is to explain our data collection and privacy practices when you use our Services. This CA Privacy Policy is incorporated in, and in turn incorporates the terms of Peerspace's general privacy policy. Please read this entire CA Privacy Policy carefully to understand our practices regarding your personal information. If you are an employee, agent, contractor, officer, director, or other personnel of Peerspace, or if we process your information as part of a business-to-business transaction, your rights under the CCPA are limited.

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain additional privacy rights related to the personal information we collect about you. Generally, the CCPA provides you with rights to know about the personal information we collect about you and rights to have personal information we collected from you deleted in certain circumstances. Please see below to learn more about your rights under the CCPA and to learn more about our practices. Not all of your personal information is subject to the CCPA. The CCPA does not apply to personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRA). Your personal information may be subject to these other privacy laws and your personal information that we maintain may be exempt from the CCPA.

  1. What Is Personal Information? The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that "identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular" California consumer or household. Personal information does not include publicly available information or consumer information that is de-identified or aggregate consumer information.

  2. What Personal Information Do We Collect About You? We collect or generate personal information about you in a number of ways depending on the relationship we have with you. Our general privacy policy describes our collection and use in more detail, but, for CCPA purposes, we may collect the following categories of information:
  • Personal Identifiers : This includes first and last name, previous name, address, telephone number, unique personal identifier, and signature;
  • Device and Online Identifiers and Related Information : This includes online identifiers, Internet Protocol (IP) address, email address, account user name, mobile/ wireless number, social media profile, unique device identifier and serial number, and other device information;
  • Demographic Information : This includes date of birth and household income data; Financial Information: This includes transaction information, financial account information used to validate your identity, account information about externally linked accounts, account login credentials, and other financial information;
  • Government Identifiers : This includes social security number, national identification number, other government-issued identification number, driver's or operator's license number, passport number, and copies of government IDs;
  • Protected Classification Characteristics : This includes age, national origin, citizenship, nationality, marital status, sex, and veteran or military status; please note that we do not collect information regarding gender identity, gender expression, or sexual orientation unless you provide it to us in connection with our products or services;
  • Purchase History : This includes customer transaction history or tendencies;
  • Internet, Application, and Network Activity : This includes text messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits and cookies or other similar technologies);
  • Location Data : We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your wi-fi connection;
  • Sensory Data : This includes audio data, such as a recording of your voice when you call us;
  • Professional or Employment-Related Information : This includes occupation, title, employer, and employment history; and
  • Inferences About You : This includes a profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes and creditworthiness profile.
  1. How Do We Use Your Personal Information? We use your personal information for the purposes described in Section III of our general Privacy Policy. We disclose the following categories of personal information to facilitate bookings and other interactions between customers, and to enable your use of the Peerspace platform: personal identifiers; device and online identifiers and related information; demographic information; financial information; government identifiers; protected classification characteristics; transaction history; internet, application, and network activity; location data; sensory (audio data); professional or employment-related information; and inferences about you. We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.

  2. What Is The Source Of The Personal Information We Collect About You? In addition to the sources described in the general Privacy Policy, we collect personal information from various sources, including consumers, advertising providers, internet service providers, analytics providers, other users, data analytics providers, government entities, credit reporting services, social networks, and vendors.

  3. Who Do We Share Your Personal Information With? We share personal information with other users, third party vendors or service providers you engage with on our site, and our trusted third party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, dispute resolution providers, advertising providers, governmental entities, social networks, and other users.

  4. Do We Sell Personal Information? California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as "sales" even if no money is exchanged. We do not sell information to third parties as defined under California law, and we have not done so for the 12-month period preceding the last revision date of this CA Privacy Policy.

  5. Rights to Know About My Personal Information? You have the right to know certain information about our collection, use, and disclosure of your personal information for the 12 months preceding the date of your request. You also have the right to request that we provide you with specific pieces of your personal information. These rights are subject to certain exceptions.Upon receipt of your request, and after we verify your identity, we may provide you with information about the following:
  • The categories of personal information we collected about you.
  • The categories of sources of the personal information we collected about you.
  • Our business or commercial purpose for collecting the personal information.
  • The categories of personal information we disclosed about you to a service provider.
  • The specific pieces of personal information we collected about you (data portability). If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that is not in conflict with applicable laws or exempt under the CCPA.
  1. Rights to Have my Personal Information Deleted? You have the right to request that we delete personal information we have collected from you, subject to certain exceptions and exemptions. Absent an exception or exemption, upon receipt of your request, and after we verify your identity, we will delete and will request that our service providers delete your personal information.

  2. How Do I Exercise My CCPA Rights? How Do I Exercise My CCPA Rights? If you are a California resident and would like to submit a CCPA request, you may submit a request via our CCPA rights portal: https://privacy.peerspace.com/consumer/index. Only you, or a person you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That individual must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.

  3. How Will You Verify My Identity If I Make a CCPA Request? In order to verify your identity, we will obtain certain information from you and use it to verify your identity using reasonable methods. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identity verification service. We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.You are not required to have an account with us to make a verifiable request.

  4. CCPA Non-Discrimination Rights? We will not discriminate against you for exercising any of your CCPA rights, which means 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.
  1. Contact Us. If you have any questions or concerns about this CA Policy, please contact us at [email protected]