Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.
DEFINITION OF TERMS
The following are the definitions of the terms used in this Policy:
The Data Privacy Act of 2012.
Data Protection Officer or DPO
An individual designated by the head of agency or organization to be accountable for its compliance with the DPA, its IRR, and other issuances of the NPC: Provided, that, except where allowed otherwise by law or the NPC, the individual must be an organic employee of the government agency or private entity: Provided further, that a government agency or private entity may have more than one DPO.
An individual whose personal, sensitive personal, or privileged information is processed.
The National Privacy Commission.
Personal Information and Sensitive Personal Information collectively.
Any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
Generally, this is any information that relates to a particular individual. This includes information that directly identifies that individual (e.g., name, residence address, mobile number, etc.), as well as information which that have been linked to those identifiers. This can also include information about devices that an individual uses where the information collected from those devices are linked back to the individual.
Personal Information Controller or PIC
A person or organization who controls the collection, holding, processing or use of Personal Information, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose Personal Information on his or her behalf.
The term excludes:
There is control if the natural or juridical person or any other body decides on what information is collected, or the purpose or extent of its processing.
Personal Information Processor or PIP
Any natural or juridical person or any other body to whom a PIC may outsource or instruct the processing of Personal Information pertaining to a Data Subject.
Process or Processing
Any operation or any set of operations performed upon Personal Information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
Sensitive Personal Information
The Services referenced in this Policy are the Services provided by WorkHaven.
INFORMATION WE COLLECT
The Personal Data 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
WorkHaven requests different types of Personal Data 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:
8.1 Device identifiers, such as IP address, WiFi MAC address, and Bluetooth address;
8.2 Geolocation information, such as through your mobile device’s GPS signal or WiFi signal, and information about your contacts, depending on your device settings;
8.3 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, and your offline activity, including information about events you attend; and
8.4 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, meeting rooms, common area 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.
9. Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the time and purpose of your visit, photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. We will also process Personal Data included in content and information that you add to your member network or other community profile. References to “Other Personal Data” in this Policy refer to all Personal Data referenced in this Policy.
INFORMATION COLLECTED ABOUT YOU
Social Media. WorkHaven collects Personal Data to enable you to use online social media resources. If you register or log into your account through a third-party social media service, we may have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.
Third-Party Sources. We obtain Personal Data about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest to one of our facilities. We also may receive Personal Data about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Data or other information that we receive from or about you, where necessary to provide the Services you requested.
Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to coming to the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected through the use of Google Analytics is not combined with your Personal Data. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, WorkHaven may enable you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools transmit Personal Data to WorkHaven to enable you to access your user accounts and to enable WorkHaven to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.
ANONYMOUS, AGGREGATED, AND OTHER INFORMATION
We also collect certain information about you that is not Personal Data. 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 Data.
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 PERSONAL DATA
The processing of your Personal Data 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 Data, 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 Data 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 Data as further described in this Policy.
SHARING OF PERSONAL INFORMATION
We disclose your Personal Data in limited circumstances to 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.
Within WorkHaven. We may share your Personal Data within WorkHaven depending on where you are located and the Services that you use. WorkHaven uses your information in accordance with this Policy.
Our Community. Our Services include online and offline member communities, forums, networks, and other features through which you may share information and connect with others. This includes:
Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. We take steps to ensure that these service providers act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
Research / Survey Solicitations. From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
Third-Party Advertising Partners. We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.
Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Data to other parties:
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.
Other Parties in Connection with a Corporate Transaction. We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
Other Third-Party Partners, With Your Consent. We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.
THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES
We may partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:
Third-parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they may collect information about you, such as your IP address and the pages that you view.
Advertising providers may help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.
Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.
We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, Internet technologies, etc.) to collect information regarding your activities. We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-WorkHaven related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.
We are active on social media (e.g., Twitter, Facebook, Instagram, 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.
RIGHTS IN YOUR INFORMATION: ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
We value your rights to your Personal Data. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us at email@example.com.
We will process such requests in accordance with the DPA. To protect your privacy, WorkHaven will take steps to verify your identity before granting access or making any changes to your Personal Information.
You have the right to opt-out of certain uses and disclosures of your Personal Data as set out in this Policy, and in specific circumstances, for example related to direct marketing.
Where you have consented to WorkHaven’s use of 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 Personal Information for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, WorkHaven will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Sensitive Personal Information is otherwise required by law or contract, WorkHaven will comply with the law or contract.
EMAIL AND TELEPHONE COMMUNICATIONS
Opting-Out of Marketing Communications. We provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding operation and administration of the Services, and you will not be able to opt out of those communications, (i.e., communications regarding updates to this Policy). If you no longer desire to be contacted by us, you must terminate your relationship with WorkHaven and can no longer use our Services.
Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.
WorkHaven will retain your Personal Data 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:
The security of all Personal Data provided to WorkHaven is important to us. WorkHaven takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Data, 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 WorkHaven strives to protect your Personal Data, we cannot ensure or warrant the security of any information that you transmit to WorkHaven, 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.
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 Data for the purposes of these automated decisions.
OTHER RIGHTS AND IMPORTANT INFORMATION
WorkHaven’s facilities have CCTV installed to meet our legitimate business interests in protecting the safety of WorkHaven’s employees, members, and guests and their property. These recordings may be accessed by WorkHaven. WorkHaven may also make CCTV footage available to members and other third parties authorized by WorkHaven. 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 WorkHaven 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.
COLLECTION OF INFORMATION FROM CHILDREN
Generally, our online Services are not directed to children, and we do not knowingly collect Personal Data from children except as permitted under applicable law. If we become aware that a child under has provided us with Personal Data, we will delete such information from our files or obtain parental consent in accordance with applicable law.
This Policy does not apply to services not provided by WorkHaven. 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.
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 WorkHaven.
QUESTIONS OR COMMENTS
Your Personal Data is controlled by WorkHaven Space, Inc. If you have any questions or comments regarding our Policy, please contact us at privacy@WorkHaven.net.
WorkHaven 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 in your emails to us.
REDRESS, COMPLIANCE AND ACCOUNTABILITY
If you have an inquiry or complaint regarding this Policy or the collection or use of your Personal Data, including any rights of access, ability to limit the use or disclosure of Personal Data, or to correct or delete inaccurate Personal Data, please email privacy@WorkHaven.net. You also have the right to lodge a complaint about data protection matters with the NPC through https://www.privacy.gov.ph/complaints-main/.