Last Updated: May 14, 2019

This Privacy Shield Policy (“Privacy Shield Policy”) describes how Effecrtive Technology Solutions, Inc. DBA SpaceIQ and its subsidiaries and affiliates (“SpaceIQ”, “Company,” “we,” or “us”) collect, use, and disclose certain personally identifiable information that we receive in the United States from the European Economic Area (“EEA”), the United Kingdom (“UK”), and/or Switzerland (“Personal Data”).

This Privacy Shield Policy supplements our Website Privacy Policy located at https://www.spaceiq.com/privac... (the “Website Privacy Policy”). Unless specifically defined in this Privacy Shield Policy, the terms in this Privacy Shield Policy have the same meaning as the Website Privacy Policy.

SpaceIQ complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. SpaceIQ has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

SpaceIQ commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

We recognize that the EEA, the UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Data about customers received in the US from the EEA, the UK, and Switzerland, we have elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). We adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the US Federal Trade Commission/US Department of Transportation. If SpaceIQ shares Personal Data with a third-party service provider that processes the data solely on SpaceIQ’s behalf, then SpaceIQ will be liable for that third party’s processing of Personal Data in violation of the Principles, unless SpaceIQ can prove that it is not responsible for the event giving rise to the damage.  In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, SpaceIQ is potentially liable. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.

Personal Data Collection and Use

As a data processor, SpaceIQ provides its customers with a workplace management tool designed to improve workplace-related processes such as seat assignment and move planning, provide visibility into the allocation and use of workplace resources such as individual workspaces and meeting rooms, and support data-driven real estate strategy. SpaceIQ’s software and related services (“Services”) are made available to its customers on a software as a service (SaaS) basis.

As a data processor, we process and store personal data including name, IP address, email address, phone number, and job title (“Personal Data”) received from our customers for the purpose of delivering the Services. To fulfill these purposes, we may access the data to provide or offer the Services, to correct and address technical or service problems, to follow instructions of our customer who submitted the data, or in response to contractual requirements. 

As a data controller, we collect and process EEA and Swiss Personal Data directly from individuals, either via our publicly available websites, or in connection with our customer and partner relationships. The Personal Data collected in this context may include name, title, email address, and phone number and will be used to contact individuals who expressed interest in our Services. We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties, Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf for purposes of providing and promoting the Services including: email service, marketing, data center and application hosting, CRM, calendar, logging and analytics. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

We maintain reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield. 

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

When we process Personal Data in the context of our Services, we only process and disclose the data as necessary to provide the Services. Our customers control how the information they upload to the Services is disclosed and used, and how it can be modified. Accordingly, if you wish to request access, to limit use, or to limit disclosure of Personal Data uploaded to the Services by our customer, please contact the customer who submitted your data to our Services. If you provide us with the name of our customer that is processing your Personal Data, we will refer your request to that customer, and will support the customer as needed in responding to your request.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal Data to us using the contact information below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the. JAMS Privacy Shield Program, an alternative dispute resolution provider in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-... for more information or to to file a complaint. The services of JAMS are provided at no cost to you. We will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at http://www.jamsadr.com.

Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions or complaints relating to this Privacy Shield Policy or would like to request access to your Personal Data, please contact us as follows: privacy@spaceiq.com.

Changes To This Privacy Shield Policy

We reserve the right to amend this Privacy Shield Policy from time to time consistent with the Privacy Shield’s requirements.