WORK CLUB AND FLORENCE GUILD PRIVACY POLICY EFFECTIVE MARCH 25, 2018

Safeguarding your privacy is important to us. Work Club is committed to maintaining your trust by protecting personal information that we collect and use.

This Privacy Policy (“Policy”) describes how Work Club and its affiliated companies and subsidiaries (“we” or “us”) collect, use, and disclose your personal information in connection with any website, application, or other service that refers to or links to the Policy (collectively, our “Services”). Please read the Policy carefully before you use our Services. You should not use our Services if you are not comfortable with what is stated below, and your continued use of Services constitutes consent to the Policy and the use and sharing of your information as provided herein.

 

Personal information we collect
We collect various types of personal information in connection with the Services, namely:

  • information you provide us directly;
  • information we collect about your device(s) and your use of our Services, including through cookies, web beacons, and other internet technologies; and
  • information we obtain from third-party sources.

 

Personal information you provide us directly
We collect various types of information and content that you provide us directly. In order to enrol as a member or to access some of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, guarantor details and where applicable company or organisation name. We also collect other content and information that you provide us directly, including the content and information you may add to your member network or other community profile and photographs or other information or documentation you submit or provide us and the communications that you transmit through our networks. We collect billing and payment information you provide when you access some of our Services or purchase products and services. We also collect information that you provide us when you participate in our surveys, promotions or events. If you do not provide us with the requested information, we may be unable to deliver you the Services in full.

To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual’s consent for the disclosure of such personal information as well as the processing of the same in accordance with the terms of this Policy.

 

Information about your device(s) and your use of the services
We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information, as specified below, from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity, as explained in more detail in the section on cookies.

The information we collect in this respect is:

  • your browser type and operating system;
  • IP address and device identifiers;
  • your browsing behaviour on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
  • websites you visit before or after our websites;
  • whether you have opened or forwarded our e-mails or connected to offers or links that we send you; and
  • your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals to the extent permitted by the settings of your devices.

If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by Work Club at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.

 

Information from third-party sources
We obtain information about you from your company or organisation, including when they may create or supplement your profile for you in the member network. You can review and amend this profile at any time.

We also receive information about you from publicly and commercially available sources and other third parties as permitted by law. We may combine this information with other information we receive from or about you, where necessary to provide the Services you requested.

 

Use of personal information
We use the personal information that we collect as necessary and appropriate for the following purposes:

  • To provide our products and services. We use your personal information to provide you with the products, services, and features that you or your company or organisation have requested; to respond to inquiries we receive from you or your company or organisation; to verify your identity; in connection with a transaction that you or your company or organisation has initiated; to deliver notifications and other operational communications; and for troubleshooting.
  • To improve our products and services and to analyse how users navigate and use our products and services and individual features.
  • To manage the performance of our products and services.
  • For audit and reporting purposes, to perform accounting and administrative tasks, and to enforce or manage legal claims.
  • To deliver advertising and promotional communications, subject to any legally required consent, which we will seek at the appropriate time. For example, we may periodically contact you with offers and information about our products, services, features, and events; to send you newsletters or other information about topics that we believe may be of interest; to conduct online surveys; and to otherwise promote our products, services, features, and events. We also may deliver targeted advertisements to you, both on and off the Services.
  • For security and to protect, enforce, or defend legal rights, privacy, safety or property, whether our own or that of our employees or agents or others, and to enforce compliance with Work Club policies and to comply with applicable law and government requests.

 

Sharing of personal information
We disclose your personal information in the following circumstances to the following parties:

  • Partners. Our services are provided by partners of Work Club depending on where you are located and the services you use. Work Club shares personal information with those partners for the purposes mentioned above. These partners use your information in accordance with this policy.
  • Memberships. Our Services include online and offline member communities, forums and networks that allow you to share and connect with others. We make this possible for Work Club members by creating a profile for new members that contains your name and the name of your company or other organisation. This profile is created automatically and is accessible to other members of the forum or network, some of which include all Work Club members. You can supplement your profile by adding additional information about yourself and your company or organisation and by posting content and comments and you may be able to share your profile with a broader audience.
  • Third party suppliers. We rely on third-party service providers to perform a variety of services on our behalf. For example, we may rely on service providers to fulfil our product and service requests and answer your questions, send e-mails on our behalf, process payment card or other transactions, and analyse data to improve our products and services. To do so, we may need to share your personal information with them for the purposes described under “Use of Personal Information”.
  • Other parties when required by law and as necessary to provide and protect our services. In some instances, Work Club and our service providers disclose your personal information to law firms, auditors, consultants, the police, courts, tribunals and other law enforcement agencies:
  • to provide you with the services you or your company or organisation request, such as a disclosure of your information to a landlord in connection with a lease agreement, 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 (which may include lawful access requests by Australian and other courts, law enforcement and governmental authorities);
  • to detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our Services; or
  • there permitted by law, to protect our rights, property, and safety or that of any of our respective affiliates, business partners, customers or employees and where otherwise required by law.
  • Corporate Transaction. We will disclose your personal information to an acquirer in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with a merger or in the event of a bankruptcy reorganisation or liquidation.
  • Third-party partners, with your consent. We may request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.
  • Organisation or company request. In addition to the disclosures described in this Policy, we may share information about you with third parties when your company or organisation requests such sharing. For example, we periodically may partner with third parties to make products or services available to individual members or participating companies and organisations. If you or your company or organisation requests to participate, we may share your information with the relevant third party in connection with the requested product or service.
  • Anonymous and non-personal information. We also share with third parties information in a manner that does not identify particular individuals, for example, information that has been aggregated with other records.
    Our Services contain links to other sites that we do not own or operate. We provide links to these third-party sites as a convenience to our members. 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, which we recommend you read carefully. The collection, use, and disclosure of your personal information will be subject to the privacy policies of the third party and not this Policy.

 

Third parties that provide content or functionality on our services
We also partner with the following categories of third parties to collect, analyse, and use some of the personal information described in this Policy:

  • 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 help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behaviour, and analytics companies help us measure and evaluate the usage of our services.
  • Other content providers may offer products and services on our Services and may operate contents, promotions, or surveys on our Services.

These third parties collect or receive certain information about your use of our Services, including through the use of cookies, web beacons, and Internet technologies and this information may be collected over time and combined with information collected across different websites and online services.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative and the Digital Advertising Alliance.

 

Information Security
We have in place various procedures to safeguard your information. Although we take such steps to protect your information, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information.

 

Accessing, reviewing, and updating your personal information
To the extent provided for under applicable law, you may have the right to access your personal information and to update or correct inaccuracies in your personal information.

You may have rights to revoke consent you previously granted us with respect to processing personal information and to object to the use of your personal information for direct marketing or for other purposes that are not necessary in light of the nature of our legal relationship. Note that if you revoke your consent to such processing, we may be unable to provide you with certain aspects of the services.

If you would like to exercise any of these rights, please send an e-mail to info@workclubglobal.com or a letter to Chief Operating Officer, c/o Work Club, 99 Elizabeth St, Sydney, NSW, Australia, 2000.

 

Marketing rules
If you opt-in to receive marketing emails from third-parties, Work Club will provide your personal information to third parties, so that those third parties may directly contact you about non-Work Club products and services. If you later choose to opt-out of receiving marketing emails from third parties, please contact the third party directly and/or follow the instructions at the bottom of their marketing emails.

 

Collection of information from children
The 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. Where different age limitations apply, we comply with them.

 

CCTV
Work Club’s buildings have CCTV installed to protect the safety of Work Club’s 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. Recordings may be accessed by Work Club in the Australia and elsewhere and may be shared with competent authorities in accordance with applicable laws. 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 longer.

 

Your Rights
You have the following rights with respect to your personal data:

  • The right to withdraw consent, where applicable, you have the right to withdraw your consent at any time. For examples, if you would like to opt out of receiving electronic marketing communications, you can request your email to be marked ‘unsubscribe’ by contacting us directly and we will stop sending you communications.
  • Right of access, rectification or erasure. You have the right to request access to and gain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. You can see the data by contact Work Club directly info@workclubglobal.com.
  • Right of data portability. Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structure commonly used and machine-readable format, and also to require us to transmit it to another controller where this is feasible, technically.
  • Right to restriction of processing. You have the right to restrict our processing of your personal data where –
    You contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
    The processing is unlawful but you do not wish to have the data erased by us;
    We no longer need your personal data for the purposes of the processing, but you require such data fort eh establishment, exercise or defence of legal claims; or
    You have been objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overrising compelling legitimate grounds to continue processing.
    Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
  • Right to object to processing justified on legitimate interest grounds, where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims where we reply upon legitimate interest as a justification for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
  • Right to object to processing for marketing purposes, where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.
    You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. You may contact the Australian Information Commissioner (www.OAIC.gov.au)

 

For further information regards your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data, please contact Chief Operating Officer, c/o Work Club, 99 Elizabeth St, Sydney, NSW, Australia, 2000 or info@workclubglobal.com 

Please be advised that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for any instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request in a timely manner, as soon as possible and in any case within the applicable timeframes.

 

Changes to this privacy policy in the future
Privacy laws and guidelines are part of a constantly changing environment. We will notify you of material changes by e-mail or by posting a message on the relevant Services.

 

Questions or Comments
If you have any questions or comments regarding our Policy, please contact us at: Chief Operating Officer, c/o Work Club, 99 Elizabeth St, Sydney, NSW, Australia, 2000. Email: info@workclubglobal.com

Effective Date: May 25, 2018