Spasora Privacy Policy

Effective Date: October 1, 2021

Introduction

Welcome to the web site (the "Site") of Spasora Ltd. This Site is operated by Spasora and has been created to provide information about our company and our services for searching, pricing and finding the right vendors with the best spaces for you via the site, mobile applications and related services (together with the Site, the "Services") to our Service visitors ("you", "your"). This Privacy Policy sets forth Spasora's policy with respect to information including personally identifiable data ("Personal Data") and other information that is collected from visitors to the Site and Services.

I. Acceptance of privacy statement

Each time you access, use or browse the Sites or interact with Spasora, or click on Spasora's digital advertisements that may appear on third party sites or apps, you signify your acceptance of the then-current Privacy Statement. If you do not accept this Privacy Statement, please do not provide information to Spasora, access, use or browse the Sites, interact with, or click on Spasora's digital advertisements. Should the Privacy Statement be revised, Spasora will post the changes on the Sites and the new Privacy Statement will be effective 30 days after posting. When required by law, any material changes in the manner that we use or share personally identifiable information will apply only to information collected after posting of the revised Privacy Statement, unless we provide notice, have other communications with you or otherwise obtain your consent in accordance with applicable law.

II. Types of information collected

We may collect personally identifiable information from you including, without limitation, non-public information about you that you give to us in connection with your interactions with Spasora! and the Sites that help Spasora identify you, such as first and last name, email addresses, employer name, home and business addresses, job role, telephone numbers, information regarding the events that you book, information that you provide relating to guests for any spaces you book, billing information, credit card information, dates of birth, transaction history, bank account and routing numbers, and other non-public information.

If the Sites provide you with an option to create an account for, or to sign in to a password protected portion of, the Sites using registration information from your existing account with a social media platform, please note that doing so may cause Spasora to receive certain of your sign in information for such social media platform as well as certain of your profile information. For example, if you create an account on the Sites using your LinkedIn account, Spasora! will obtain your email address, name, photo, headline, contact information, experience, education, summary, and location contained in your LinkedIn profile. Such information will be treated as personally identifiable information so long as the information is maintained in a manner that identifies your name or contact information.

We also may collect non-personally identifiable information, including, without limitation, information that does not personally identify you as the individual to whom the information relates, such as information that is aggregated by Spasora or a third party, or information that is not linked to contact information or other personally identifiable information about you. This would include information about your use of the Sites such as your IP address(es), usage statistics, browsing and navigational history when visiting the Sites and content you access or view when on the Sites, general geographic location such as the city from which your computer or device is connecting to the Internet, webpages requested and visited, timestamps, sites you visit prior to and after visiting the Sites, type of operating system you use on your computer (e.g., Microsoft Windows or Mac OS) or device (e.g., iOS or Android) to access the site, the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider; and information regarding your Internet location if and when you see Spasora ads and whether you click on such ad.

In addition, Spasora may collect information regarding your age, gender, zip code, occupation, interests, purchase preferences, language preferences, event booking information, guest preferences, account IDs and passwords for the Sites, cursor navigation, and content you access, view, click on or search for when on the Sites, the device from which you access such content and the length of time for which you view same, information regarding the number of times your share content on the site through social plugins such as Facebook, Twitter, Pinterest, LinkedIn and Google+ as well as other information regarding your sharing of such content. In the event that such information is maintained in a manner that identifies your name or contact information, it will be treated as personally identifiable information; otherwise, such information will be treated as non-personally identifiable information.

III. How we collect information

We may collect personally identifiable information about you during your online and offline interactions with Spasora and the Sites, such as when you:

  • • Book a space;
  • • Provide information regarding space guests;
  • • Create, change or use an account or user profile;
  • • Sign up to receive emails, promotions, alerts, announcements or newsletters;
  • • Apply for jobs via the Sites or email;
  • • Participate in any events, promotions, sweepstakes, surveys, questionnaires, or other activities (collectively, "Activities");
  • • Communicate with Spasora via the Sites or email; and
  • • Interact with Spasora personnel, whether in person, on the telephone or via email.

Spasora automatically receives and records non-personally identifiable information on our server logs from your browser as well as through other analysis of the Sites. If you are logged in to your Spasora account we also may collect additional personally identifiable information such as content you access, view, click on or search for when on the Sites, the devices from which you access such content and the length of time for which you view same.

We also may collect information using cookies, web beacons, pixels, gifs, tags, browser web storage, application data caches or similar technologies (collectively, "Collection Technology") or through third parties using cookies or other Collection Technology. A cookie is a piece of data stored on your computer or device. When you visit the Sites, your web browser may store cookies on your computer or device, or your computer or device may be exposed to other Collection

Technology which work independently or in conjunction with cookies. Cookies or other Collection Technology will better enable you to navigate the Sites upon an initial visit or return visit, and will collect certain information about you. You may use the Sites even if you choose to reject or delete the cookies. Cookies also may be used by some of the other site for which a link is placed on the Sites.

Now or in the future, the Sites may use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies and other Collection Technology to collect and store anonymous information about you, which may include non-personally identifiable information. You can read Google Analytics' privacy policy at http://www.google.com/analytics/learn/privacy and Google Analytics Terms of Use at http://www.google.com/analytics/tos. The Sites may use certain features of Google Analytics based on Display Advertising, such as:

  • • "Demographics and Interest Reporting" to analyze information regarding the interests and demographics of users of the Sites. We use such non-personally identifiable information in the same manner as we use other non-personally identifiable information as described below.
  • • "Remarketing with Google Analytics" to place ads on other sites directed to people who have visited the Websites.
  • • "Google Display Network Impression Reporting" to report how people's interactions with our ads relate to their visits to the Sites.

You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings at: https://www.google.com/settings/ads. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at: http://tools.google.com/dlpage/gaoptout?hl=en.

Spasora also may acquire personally identifiable and non-personally identifiable information from other sources (such as offline records or publicly available information), from third parties such as our business partners, Activities partners and sponsors, vendors, merchants and other third parties; and the owners or operators of sites or applications where our advertisements appear, some of which partner with Spasora or with an advertisement network used by Spasora. Non-personally identifiable information also may be obtained by these other sources from inferences based upon the sites you visit; third party data; information you share on other sites, social media platforms and applications; or demographics derived from profiles or accounts that you create, to the extent permitted in their privacy policies.

IV. How we use your information

We may use the information we collect:

  • • For the purposes for which you provided the information;
  • • To process and respond to your event bookings, requests and inquiries and provide services to you;
  • • To alert you to new developments, promotions, specials, special events, products or services or other Activities and to administer same;
  • • To send you announcements, promotions, and newsletters, and to personalize same;
  • • To monitor and analyze information regarding your browsing and viewing preferences and to diagnose problems of the Sites;
  • • To carry out internal operations and to analyze our users' demographics and interests;
  • • To administer and process payments;
  • • For administration and improvement of the Sites and to enhance the user experience and Spasora's services;
  • • To develop, deliver, and improve our services, content, and advertising;
  • • To send important notices, such as communications about space bookings and other transactions on the Sites and changes to our terms, conditions, and policies;
  • • For fraud prevention, internal operations, legal compliance, and other public and security related purposes; and

Spasora may combine personally identifiable information collected through the Sites with information available from other sources (such as offline records or publicly available information). We will treat the combined information as personally identifiable information. Unless otherwise provided in our contract with you or pursuant to legal requirements, Spasora stores all information collected until you instruct us in writing to remove personal information from our systems.

Spasora also may use your non-personally identifiable information to present you with targeted content and advertisements (including on third party sites and apps) based on your past visits to the Sites and non-personally identifiable information collected over time by us and third parties. Such targeted content and advertisements may include marketing for the Sites our services, or the sites, products and services of Spasora's business and advertising partners. Your non-personally identifiable information also may be used to analyze and develop advertisements and advertising campaigns, provide you with special offers and promotions and determine the effectiveness of same, optimize and determine the effectiveness of content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how same relates to your visits to the Sites.

V. Information sharing with third parties

Spasora may disclose the information it collects to others (i) that are merchants or vendors being engaged for the purpose of effectuating a space you booked or have inquired about; (ii) for purposes of outsourcing one or more of Spasora's functions to service providers who work on behalf of or with Spasora, including agents, vendors, merchants, advertisers, consultants and affiliates; (iii) to confirm or update information provided by you; (iv) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Spasora's business or operations (including without limitation in connection with bankruptcy or any similar proceedings); (v) that are its business partners, activities sponsors or partners for our internal purposes; or (vi) as otherwise authorized by you.

Spasora also may share the information it collects with Spasora's business partners, merchants and vendors or other third parties for their direct marketing purposes.

We also may share your information in response to a subpoena, legal order or official request, when we believe you have acted in violation of the Terms of Use or supplemental terms and/or policies of Spasora, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or to exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of Spasora, or others, or as otherwise permitted or required by law.

Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with third parties, advertisers and/or business partners to analyze the Sites' usage or demographics, or improve our products or services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.

The Sites may provide an option to create an account or to sign in using an email address and password that you have already registered with a social media platform, and/or may contain social plugins for other websites, such as Facebook, Twitter, Pinterest, LinkedIn and Google+. Prior to creating an account or signing in using such method and/or clicking on such plugins, we recommend reviewing the privacy policies for each of these websites/social media platforms.

Spasora will not use the email addresses of any Spasora Guest space invitees for remarketing purposes. Additionally, Spasora will not sell or otherwise provide said invitee email addresses to any third party.

VI. Communications with you

You authorize Spasora to send email to you or telephone you to respond to your communications, and provide information to you about specials, promotions, new developments, special events, other activities or services. Where required by applicable law, we will seek your prior written consent before doing so. Unsubscribe instructions will be included in each promotional email from Spasora. Please note that unsubscribe requests may take up to 10 days to become effective. Unsubscribing will not stop you from receiving communications regarding your dealings with the Sites, transactions with Spasora or technical information about the Sites.

VII. Links

You may have the opportunity to follow links on the Sites to other sites that may be of interest to you. Spasora endeavors to only link to reputable organizations. Because other sites may not be hosted or controlled by Spasora responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other sites may differ from those applicable to the Sites. We encourage you to review the privacy policies of each other site. This Privacy Statement only applies to information collected and maintained by Spasora.

VIII. Protection of personally identifiable information

Spasora uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of your information. No transmission of data over the internet is guaranteed to be completely secure. While we strive to protect personally identifiable information, neither Spasora nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk. Spasora may process personally identifiable information on a server located outside the country where you live.

IX. Updating your information

You are responsible for keeping your information current and up-to-date. You may update your information by modifying your account user profile and/or contacting us via the contact section. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Spasora's internal reporting, processing and retention policies and all applicable legal obligations. You also have the right, where provided under applicable law, to ask us not to process your personal data by contacting us via the contact section. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort and provided same is allowed under applicable law.