PRIVACY POLICY

About this Privacy Notice

We are YourSpaceUSA, LLC (also known as “Introu”), a company registered in Delaware. We take the privacy of your information very seriously. This notice is designed to tell you about our practices in connection with information that we or our third-party service providers collect through certain of our owned or controlled websites, web properties (e.g., widgets and applications), email, telephone and mobile applications (“Mobile Apps”) in each case, that link to this Privacy Policy (each, a “Property” or collectively the “Properties”). By providing Personal Information (as defined below) to us through the Properties, you agree to the terms and conditions of this Privacy Policy.

In general, our services relate to the provision of our Introu platform to users. Through our platform, individual professional freelancers (each a “Freelancer”) can register and once a member, they can then join co-working space(s) (each a “Workspace”) in exchange for providing their time, skills and professional expertise to other third party businesses who have also registered and are a member of the platform (each a “Business”). The Business can then make bookings for the Freelancer's professional services using the platform in relation to ad-hoc projects, one-off services or consultations (“Freelancer Services”). Please visit the website for more information on the offerings we provide.

This notice therefore applies to Personal Information provided by or otherwise collected and in relation to: 1) our users who are simply visiting the website or otherwise making and enquiry with us; 2) the Freelancers and Businesses who have registered with us and are members of the Introu platform; 3) the Workspaces; and 4) third party suppliers of Introu; but this notice does not apply to information we hold in relation to our employees and staff. In this notice “ you ” refers to any individual whose Personal Information we hold or process.

This privacy notice is governed by applicable US Federal law, individual State Law including, but not limited to:

Your California Privacy Rights: If you are a California resident, you may request certain information once per year about our disclosure of certain categories of Personal Information during the preceding calendar year to third parties for such third parties' own direct marketing purposes. Please send your request by email to Hey@introu.co, or by mail to 1216 Broadway, Suite 424, New York, N.Y. 10001._We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

If you are in the European Union the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation. This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Personal Information we collect and how we process this data

Below we have set out the categories of Personal Information we collect, the legal basis we rely on to process the data and how we process the data:

  • Contact and registration information of our users who: 1) have registered with us; 2) submit an enquiry to us; or 3) subscribe to our newsletter. Contact information may include your name, surname, company name, job title/role, email address, username, address and telephone number (“ Contact Information ”).

    If you subscribe to a newsletter or other regular information we provide, we will process your Contact Information on the basis that you have consented to this and will only send our newsletter to you for as long as you continue to consent.

    Otherwise, we process this information to provide our services and communicate with you (including with respect to customer care and support) on the basis of performing our contract with you or on the basis of our legitimate interest in providing our services to you.
  • Profile information which we hold because you are a Freelancer or a Business that is registered as a member to the Introu platform (“ Profile Information ”) and which we process during the course of providing our services to you. If you are a Freelancer, the information may include details of your education, professional title, qualifications, skills, experience and expertise. Alternatively if you are a Business, the information may include details of the specific requirements you are after in relation to the Freelancer Services, and such information may include Personal Information.

    We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
  • Booking information which we hold because you are a Freelancer or a Business that is registered as a member of the Introu platform (“ Booking Information ”) and which we process during the course of providing our services to you. If you are a Freelancer, the information may include details of your bookings, the details of the booking, e.g. date, time, location and brief. Alternatively, if you are a Business, the information may include details of the Freelancers which you are booking, the details of the booking, when the booking was made and the information that you made a booking.
  • A record of any correspondence or communication between you and us (“ Communication Information ”).

    We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
  • Financial information which we hold in the context of providing/receiving services from you (“ Financial Information ”) such as billing and banking information.

    We process this information when we provide or receive services (as the case may be) on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
  • Information which we hold because you are a third party supplier relevant to the services we provide to our Introu platform members (you may for example be a payment processor or marketing software provider) (“ Supplier Information ”).

    We process this information (including contact and financial information), on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
  • Cookie Information . A cookie is a small text file which asks permission to be placed on your computer's hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

    Where applicable and necessary, we process Cookie Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests. Otherwise and for other technical information (such as IP address data), we process this on the basis of our legitimate interest in providing our services to you. For more information, please see our Cookies and IP address section below.
  • Marketing information . We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (“ Marketing Information ”).

    We process this information in order to improve our services, communicate with you about our services or for market research purposes, on the basis on the basis that you have consented to receiving the information or in certain limited circumstances, on the basis of our legitimate interests in communicating with you about our services.

We will generally collect information from you directly or from publicly available information however if we obtain your Personal Information from a third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this privacy notice.

Data Retention

We will retain your Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.

The criteria we use to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide our Platforms to you (for example, for as long as you have an account with us or keep using the Platforms)

Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them)

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations); and

Any guidelines issued by relevant legal and data protection authorities.

Sensitive Information

We ask that you not send us, and you not disclose to us, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Properties or otherwise.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

  • protecting our servers by both hardware and software firewalls;
  • locating our data processing storage facilities in secure locations;
  • encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  • when necessary, disposing of or deleting your data so it is done so securely;
  • regularly backing up and encrypting all data we hold.

We will ensure that our employees and staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees or staff of third parties working on our behalf are also aware of their privacy and data security obligations.

This notice and our procedures for handling Personal Information will be reviewed as necessary.

Cookies and IP Address

Like most websites and apps, we use cookies to help provide you with the best experience whilst using our service. The cookies we use are split between the following categories:

  • Strictly necessary cookies - which are an essential part of our service and affect the way you can use our site (e.g. security & authentication)
  • Performance cookies - which are used for analytics (e.g. understanding usage on our website)
  • Functionality cookies - which collect information about your device to help you customize our service (e.g. remembering your username, language, time zone settings or accessing inline help)

On your first visit to our site from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for “strictly necessary cookies”, until you have provided your consent by clicking the “Accept” button. If you click the “Accept” button on our cookies notice, Performance and Functionality cookies will also be loaded.

Below is a list of the cookies currently set by us:

Cookie Type

Cookie Filenames

Purpose

Active on this site

More Information

Essential Site Cookies

Various

Site cookies are essential to the operation of this website. They are usually set when you first visit the site and deleted when you close your browser. If blocked, this site will not operate correctly

Yes

n/a

Google Analytics

_utma, _utmb, _utmc, _utmz

These cookies are used to collect information about how visitors use our site. The information is used to compile reports that let us improve the site. The information is collected in any anonymous form, including the number of visits to this site, how you arrived at the site, and which pages you visited.

Yes

You can opt-out of these cookies by following this link: tools.google.com/dlpage/gaoptout

Adverts

Various

Our advertisers may use cookies to serve you with adverts based on your previous search and web usage. These cookies are not used directly by Yourspace UK Limited.

Yes

You can visit www.youronlinechoices.com/uk/your-ad-choices for more information on how the information is used, and how you can block them.

As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.

Refusing Cookies

You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.

IP Address

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site's privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

Other Information We May Collect

We and our third-party service providers may collect Other Information (defined above) such as:

• Browser and device information

• Mobile App usage data

• Server log files

• Information collected through cookies, pixel tags and other technologies. If you are located within the EEA please read our cookie policy above for further details on our use of cookies.

• Geographic location information

• Demographic information and other non-personally identifiable information provided by you

• Information about how you use the Properties

• Aggregated information

How We May Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in “How We May Collect Other Information” section above, as well as for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

Your privacy rights

With respect to your Personal Information, you have:

  • The right to withdraw consent - the right to withdraw any permission you have given us to process your Personal Information

All Data Subject Access Requests and other requests or notifications in respect of your above rights must be sent to us in writing via by email at hey@introu.co or by mail to Data Officer, YOURSPACEUSA, LLC, 1013 Centre Road, Suite 403S Wilmington, Delaware 19805 , Attn: Greg Feld-Davidovici.

We will endeavour to comply with such requests as soon as possible but in any event we will respond within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Sharing your information: Other Uses and Disclosures

We may also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law.

o This can include laws outside your country of residence.

• To respond to requests from public and government authorities.

o These can include authorities outside your country of residence.

• To cooperate with law enforcement.

o For example, when we respond to law enforcement requests and orders.

• For other legal reasons.

o To enforce our terms and conditions

o To protect our operations or those of any of our affiliates or artists;

o To protect our rights, privacy, safety or property, or that of our affiliates, our artists, you or others; or

o To allow us to pursue available remedies or limit the damages that we may sustain.

• In connection with a sale or business transaction.

o We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors

Data breaches

If Personal Information we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed).

If a breach is likely to result in a high risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside the UK or EEA

We will not transfer your Personal Information in a systematic way outside of the United States but there may be circumstances in which certain Personal Information is transferred outside of the United States, in particular:

  • From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the United States . In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
  • If you use our services while you are outside the United States, your information may be transferred outside the United States in order to provide you with our services or communicate with you.
  • We may communicate with individuals or organisations outside of the United Statesin providing our services. Those communications may include Personal Information (such as contact information).
  • From time to time your information may be stored in devices which are used by our staff outside of the United States (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the United States, and the third country or international organisation in question has not been deemed by the United States to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Cross-Border Transfer

The Properties are controlled and operated from the United States; accordingly, this Privacy Policy, and our collection, use and disclosure of your Personal Information, is governed by the laws of the United States, and the Properties are not intended to subject Company or any of its affiliates to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Properties you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

If you are located in the EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission regarding Personal Information. You may obtain a copy of these measures by contacting privacypolicy@wmg.com or consult standard terms by following this link.

The Properties are not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through the Properties.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available on or through a Property.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your Personal Information or how it is handled, you can do so by email at hey@introu.co or by mail to Data Officer, YourSpaceUSA, LLC YOURSPACEUSA, LLC, 1013 Centre Road, Suite 403S Wilmington, Delaware 19805 , Attn: Greg Feld-Davidovici

Complaints

If you have any questions or concerns about this Privacy Policy or our Privacy Policy and/or data processing practices, please contact us by email at hey@introu.co

Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.