Privacy Policy

Effective Date: March 30, 2021

SCOPE

This Privacy Notice applies to personal information processed by Common Room, Inc. (“Common Room,” “we,” “us,” and “our”) through our website and related Common Room offerings. To make this Privacy Notice easier to read, our website and related offerings are collectively called the “Services.”

An Important Note: This Privacy Notice does not apply to any of the personal information that our customers may process using Common Room’s products and services (“Customer Data”). Our customers’ respective privacy policies govern the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with our Services.

Information You Provide to Us

Your Communications with Us. We collect personal information from you such as your email address, phone number, or mailing address when you request information about or a demo of our products and services, sign up for marketing from us, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Interactive Features. We may offer interactive features such as blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Common Room. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Common Room.

Information Collected Automatically

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services.

Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“ Technologies ”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

• Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  
• Analytics. We may process analytics information on our Services, including through the use of Technologies.

Information from Other Sources

We may obtain information about you from other sources, including from third-party services and organizations.

HOW WE USE YOUR INFORMATION

We use your personal information for a variety of business purposes, including:

To Provide the Services or Information Requested, such as:

• Fulfilling our contract with you;
• Responding to questions, comments, and other requests;
• Allowing you to register for events;
• Providing access to certain areas, functionalities, and features of our Services; and
• Answering requests for customer or technical support.

Administrative Purposes, such as:

• Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Measuring interest and engagement in our Services;
• Improving the Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Carrying out audits;
• Communicating with you about your account, activities on our Services and Privacy Notice changes;
• Preventing and prosecuting potentially prohibited or illegal activities;
• Enforcing our agreements; and
• Complying with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party sites.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.

Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.

Affiliates. We may share personal information with Common Room’s affiliated entities.

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

YOUR CHOICES

General. You may be able to opt out of certain uses of your personal information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Notice).

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

“Do Not Track”. Do Not Track (“ DNT ”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing 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) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We store the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

For privacy and compliance reasons, we reserve the right to delete inactive instances (those without web application usage).

SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“ CCPA ”). The CCPA provides California residents with the right to know what categories of personal information Common Room has collected about them and whether Common Room disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Common Room

Categories of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

• Service providers

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

• Service providers

Commercial information

• Service providers

Internet or other electronic network activity

• Service providers

Professional or employment-related information

• Service providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Common Room does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third party websites or applications is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please contact us at support@commonroom.io.