Effective Date: 25 August, 2018
Before you use our Services, please read this Policy in its entirety, which helps you make informed decisions about your relationship with us.
- INTRODUCTION “Co-working Office Space” means the room number(s) and/or workspace location(s) specified in the Membership Agreement.
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 any means reasonably available to us.
Our Services. The Services referenced in this Policy include the Services provided by The Aisle as defined and specified in the Membership Agreement or communicated to you by The Aisle.
References to “you.” In this Policy, “you” means anyone who uses 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.
- INFORMATION WE COLLECT
The Personal Information that we collect and how we use that information depend on your relationship with us and the requirements of applicable law as described below.
We collect information:
- that you provide to us directly including but not limited to your name, payment and contact information
- information that may be gathered from our security cameras located on the Premises
- about your devices and their location, and your use of our Services, including through cookies, web server logs, pixels, web beacons, and other Internet technologies. For more information about these technologies, please see our cookies policy at theaisle.work/legal/cookies;
- that we obtain from other sources; and
If you opt in to certain features, we obtain geo-location data, photos and information about your contacts.
INFORMATION COLLECTED ABOUT YOU
We request different types of Personal Information from you, 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:
- Contact Information, including your name, mailing address, phone number, email address and other information that enables us to contact you;
- Verification Information, including a photo ID or government issued identification, and date of birth;
- Professional Information, including your company name, title, role, team and other information about your profession;
- Payment Information, including your credit card details, bank account information, and payment or other information required when you make payment to us;
- Intellectual Property, including trademarks, logos, and other intellectual property that you own;
- Other Personal Information, including instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the purpose of your visit, 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 Information included in content and information that you add to your member network or other profile.
- Email Calendar Information. We may integrate with your corporate email calendar (Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book.
- Office Preferences. You provide us with your office preferences, such as temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences related to the Services.
- Communications. We also collect and store communications, such as e-mail, SMS, Slack, requests made through Amazon Echo or similar technology, calendar invitations, any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services.
INFORMATION COLLECTED FROM SOURCES OTHER THAN YOU
- Information from Third-Party Sources. We obtain Personal Information about you from your company, organisation, agent, broker, parent, or guardian; or from your host if you are a visitor or guest to our Premises. We also may receive information about you from publicly and commercially available sources and other third parties as permitted by law. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.
- Google Analytics. We use a tool called “Google Analytics” to collect information about 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 Information. Learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/.
- Information Used for Interest Based Advertising. Through the Website Services, we allow third-party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address or page(s) visited). 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-The Aisle related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” For more information on these types of tracking tools, please see our cookies policy at theaisle.work/legal/cookies.
- 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 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, The Aisle enables 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 Information to The Aisle to enable you to access your user accounts and to enable The Aisle to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.
ANONYMOUS AND AGGREGATED INFORMATION We also collect and/or generate anonymised and aggregated information from your use of the Services. We use anonymised and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymised or aggregated information is not Personal Information.
- USE OF PERSONAL INFORMATION How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:
- provide you with our Services and any directly related purpose, in order to meet our contractual obligations to you or your business entity;
- contact you about our Services and promotions. We 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 these promotions, where permitted by applicable law. We ensure that we do not use your Personal Information in ways you would not expect by allowing you to opt out of receiving all such communications (unless they are solely related to the provision of our Services to you and have no marketing element) and, where required by applicable law, we will not send any such messages without your prior consent;
- create, manage and terminate membership
- perform internal review, audit, accounting and administrative tasks
- communicate with you, respond to and follow up on your enquiries;
- notify you of changes to our Services, Terms and Conditions and House Rules that may affect you;
- process billing and payments;
- conduct surveys, research and perform statistical analysis and
- comply with our legal obligations. Among other things, we use Personal Information to comply with financial reporting obligations, or court orders, warrants, or subpoenas in accordance with applicable law.
If you provide us with your Personal Information, we intend to use it for direct marketing purpose to offer or advertise the availability of our goods and/or services. However, we may not use your Personal Information for such purpose unless we have received your consent to our intended use.
If you do not wish us to use your personal information in direct marketing, you may opt out of our direct marketing at any time by send us an email to our Administrative Officer at firstname.lastname@example.org. We must, without charge to you, cease to use your personal information in direct marketing if you so require.
We will use the personal information supplied by you for direct marketing only in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance”). Our direct marketing materials may come in several forms, including but not limited to marketing emails and text messages.
Remember that in certain circumstances — in particular where we use Personal Information on the basis of our legitimate interests or your consent — and where permitted by applicable law, you have the right to object to our uses of your Personal Information.
- SHARING OF PERSONAL INFORMATION We disclose your Personal Information in limited circumstances to our affiliates, our service providers and advertisers, and other end users, in order to provide our Services and to improve ways of working in our Co-working Office Space. We do this for the purposes outlined above. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.
- The Aisle Member Network. Our Services include online and offline member communities, forums and networks that allow you to share information and connect with others. We make this possible by creating profiles for members or permitting members to create their own profiles. Such a profile contains your name and the name of your business entity or other organisation and other information you provide. Depending on the Services you use, this profile might be created automatically and is accessible to other members of The Aisle. You can supplement your profile by adding additional information about yourself and your company or organisation. You can share your profile with a broader audience (e.g., via social media). Please note that we cannot control the actions of other users of the Services with whom you share information.
- Service Providers. We rely on third-party service providers to perform a variety of services on our behalf, and we take steps to ensure that they act only in line with our instructions and on our behalf, or otherwise to use Personal Information as described in this Policy. Examples of these service providers include entities that process credit card payments, and provide web hosting, advertising and marketing services.
- Third parties through social networks, widgets and plug-ins. If you use any features made available to you on our website by a third party it may result in information being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” us and may post that information on Facebook.
- Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Information to other parties:
- to provide you with the Services that you or your company or organisation request, or to auditors or consultants;
- to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement;
- to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services;
- to protect our rights, property, and safety or that of any of our affiliates, business partners, members or employees; or
- 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.
- 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 reorganisation or liquidation. Following such a corporate transaction, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information.
- Third-Party Advertising Partners. We share limited Personal Information with third parties that serve our advertising online, so that they can display our adverts to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively. We make sure that we only share limited Personal Information for this purpose, and only to trusted partners that are restricted in how they can use your Personal Information.
- 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 publicise your name, likeness and other personal characteristics and private information for advertising, promotion and other commercial and business purposes.
- Research / Survey Solicitations. From time to time, we will provide your Personal Information to our service providers 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.
4.1 THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES We partner with certain third parties to collect, analyse, 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 collect information about you, such as your IP address and the pages that you view.
- Advertising providers 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, or surveys on our Services.
- Public Forums. Our Sites may make member networks, chat rooms, forums, and/or other groups available to the 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 unauthorised third party’s use of information that you disclose online.
- Social Media. We are active on social media (e.g., Instagram, 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.
- 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; (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 The Aisle, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please send us an email to our Administrative Officer at email@example.com.
We will process such requests in accordance with the Personal Data (Privacy) Ordinance (Cap. 486). To protect your privacy, We will take steps to verify your identity before granting access, or making any changes to your Personal Information.
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 our 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 are able to withdraw that consent at any time.
Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Personal Information for a purpose other than its original purpose or the purpose authorised subsequently by the Data Subject, we 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, we will comply with the law or contract.
6.2 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, e.g., communications regarding updates to our House Rules or this Policy. If you no longer desire to be contacted by us, you must terminate your relationship with The Aisle 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.
6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE Should The Aisle 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 Aisle’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/
INTERNATIONAL TRANSFERS We may transfer the Personal Information we collect about you to countries other than the country in which the information was originally collected. Those countries may have privacy protections less stringent than the country or jurisdiction in which you initially provided your Personal Information. 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 sending an email to our Administrative Officer at firstname.lastname@example.org.
RETENTION The Aisle 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:
- Continue to develop, tailor, upgrade and improve our Services;
- Maintain business records for analysis and/or audit purposes;
- Comply with record retention requirements under the law;
- Defend or bring any existing or potential legal claims; or
- Address any complaints regarding the services.
INFORMATION SECURITY The security of all Personal Information provided to The Aisle is important to us. The Aisle takes reasonable steps endeavoring to use appropriate technical or organisational measures to protect your Personal Information, including against unauthorised 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 Aisle strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to The Aisle, 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.
AUTOMATED PROCESSING We do not currently use your Personal Information in such a way that automated decisions are made about you without any human input.
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, and request that we restrict the use of your Personal Information for the purposes of these automated decisions.
- OTHER RIGHTS AND IMPORTANT INFORMATION 11.1 CCTV Our Premises have CCTV installed to meet our legitimate business interests in protecting the safety of our employees, members, and guests and their property, as well as to improve our products and services, and to analyse how users navigate and use our spaces. These recordings may be accessed by The Aisle and its Members with a need to know. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are retained for a limited period of time, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them.
11.2 COLLECTION OF INFORMATION FROM CHILDREN Generally our Services are not directed to children under the age of 18, and we do not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without parental consent, he or she should contact us by sending an email to our Administrative Officer at email@example.com. If we become aware that a child under 18 years old has provided us with Personal Information, we will delete such information from our files.
11.3 LINKS We display advertisements and other content from third parties or partners that links 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. 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.
11.4 CHANGES TO THIS POLICY IN THE FUTURE Any information that is collected via the Services is covered by this 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 member network 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 The Aisle.
11.5 QUESTIONS OR COMMENTS
If you have any questions or comments regarding our Policy, please contact us at:
The Aisle Limited 6/F, Shui Hong Industrial Building Nos. 543/549 Castle Peak Road, Hong Kong Email: firstname.lastname@example.org
We 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.