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Privacy Policy ________________________________________ Safeguarding your privacy is important to us. WBC Office Suites is committed to maintaining your trust by protecting personal information that we collect and use. If you live or are based in the United States, this Privacy Policy (“Policy”) describes how WBC Office Suites LLC and its affiliated companies and subsidiaries ("WBC Office Suites", “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 practices we describe in this Policy and the use and sharing of your information as provided herein. 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. For example, in order to enroll 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, and where applicable company or organization 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, sweepstakes 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 behavior 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 WBC Office Suites 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 organization, 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. For further details, see below: 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 organization have requested; to respond to inquiries we receive from you or your company or organization; to verify your identity; in connection with a transaction that you or your company or organization has initiated; to deliver notifications and other operational communications; and for troubleshooting. • To improve our products and services and to analyze 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. 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 WBC Office Suites 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: • Among WBC Office Suites companies. Our services are provided by affiliates of WBC Office Suites LLC depending on where you are located and the services you use. WBC Office Suites shares personal information with those affiliates for the purposes mentioned above. These affiliates use your information in accordance with this policy. • Our Community. 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 WBC Office Suites members by creating a profile for new members that contains your name and the name of your company or other organization. This profile is created automatically and is accessible to other members of the forum or network, some of which include all WBC Office Suites members. You can supplement your profile by adding additional information about yourself and your company or organization and by posting content and comments and you may be able to share your profile with a broader audience. • Service Providers. 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 host data and platforms, fulfill our product and service requests and answer your questions, send e-mails on our behalf, process payment card or other transactions, and analyze data to improve our products and services. • Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your information to other parties: o to provide you with the services you or your company or organization request, such as a disclosure of your information to a landlord in connection with a lease agreement, or to auditors or consultants; o to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement; o to detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our Services; or o 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. • Other Parties in Connection with a 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 reorganization 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. • Other Parties at Your Company’s or Organization’s Direction. In addition to the disclosures described in this Policy, we may share information about you with third parties when your company or organization 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 organizations. If you or your company or organization requests to participate, we may share your information with the relevant third party in connection with the requested product or service. • Aggregated 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 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 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 may offer products and services on our Services and may operate contents, sweepstakes, 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 to learn more. Further information in local languages may be available at Your Online Choices. 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. Reviewing and Updating Your Information In accordance with applicable law, you may have the right to access, update, or correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. If you would like to access, review, or update your information, please e-mail [email protected] 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 in light of the nature of our certain aspects of the services. If you would like to exercise any of these rights, please send an e-mail to [email protected] or a letter to Privacy Director, WBC Office Suites, 1087 Elm Street Suite 201 Manchester, NH 03101. International Transfers The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to another country in accordance with applicable law. By using the Services, you consent to the collection, international transfer, storage, and processing of your information. Your California Privacy Rights You may opt out of having your personal information shared with third parties for those third parties’ direct marketing purposes by e-mailing [email protected]. Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals. California residents who are registered members or users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at [email protected]. In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code) and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party. Collection of Information From Children The Services are not directed to children under the age of 16 and we do not knowingly collect personal information from anyone under the age of 16. Persons over 16 but under 18 years of age should ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet. Changes to This Privacy Policy in the Future Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. We encourage you to review this Policy periodically to ensure that you are aware of our current privacy practices, although we may also elect to notify you by e-mail or by posting something on some or all of our online Services. Your continued use of our Services following any changes signifies your acceptance of these changes. Questions or Comments If you have any questions or comments regarding our Policy, please contact us at: Privacy Director, WBC Office Suites, 1087 Elm Street Suite 201 Manchester, NH 03101 Effective Date: September 1, 2016