Last updated: January 12, 2022
Welcome to Ledger! The security of all Personal Information (defined in paragraph 3) provided to Ledger is important to us. We take reasonable steps to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage.
By using our Services or providing Personal Information to us, you agree that we may communicate with you regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
3. What Types of Data Ledger Collects. We collect certain Personal Information, which means data that relates to you and can—either on its own or in combination with other information—identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.
We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.
Ledger may collect and generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.
Ledger collects Personal Information including:
Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you
Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth
Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession
Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase
Email Calendar Information, should Ledger integrate with your email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book
Office Preferences, including your requested or preferred temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences related to the Services
Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use. These include services such as printer or Wi-fi usage, and desk or conference room bookings
Communications, and any other information that you intentionally share with Us, send, or receive using the Services, including your email, SMS, Slack, requests made through feedback platforms, automated chatbots or similar technology, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services
Device and Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:
Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address
Geolocation information, such as through your mobile device’s GPS signal or WIFI signal, and information about your contacts, depending on your device settings
Information about your online activity, including information collected using standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies
Information gathered by sensors about how you use our Services, including through Spatial and People Analytics Sensors in offices, kitchens, conference rooms, and other spaces of some facilities that you may work in or visit, to promote more efficient and comfortable uses of the Services. Examples of SPA Sensors include desk occupancy sensors, environmental sensors, WiFi network hubs, and optical camera-powered sensors
Social Media. We collect Personal Information to enable you to use our Member Portal and Services. If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service.
Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest to one of our spaces. We also may receive your Personal Information from publicly and commercially available sources, as permitted by law and other third parties with whom we have an arrangement. We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested.
Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the use of our Website Services (e.g., Google Analytics collects information such as how often users visit the Website Services, what pages they visit when they do so, and what other sites they used prior to visiting the Website Services). Google Analytics collects only the IP address assigned to you on the date that you visit the Website Services, rather than your name or other identifying information. The information collected using Google Analytics is not combined with your Personal Information. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords for Our systems, relationship to emergency point of contact, vehicle identification, bicycle identification, and other details such as the time and purpose of your visit, photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. We will also process Personal Information included in content and information that you add to your member network or community profile.
4. How Ledger Uses Your Data. How Ledger uses your Personal Information depends on your relationship with us. In general, we use your Personal Information to: provide you with our products and Services, including online and offline events, and other materials you request; protect against fraud, abuse, or harm; respond to or fulfill customer service requests; analyze or improve our products and Services; contact you about our Services, promotions, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you through various means, which may include by email, telephone, postal mail, or by other means as communicated to you from time to time; and comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.
5. Who Ledger Shares Your Data With. We share your Personal Information in limited circumstances to Ledger, our community, our service providers and advertisers, to provide our Services and to improve ways of working in our community, and where required by applicable law. Where required by applicable law, we will only share your Personal Information with third parties with your consent. We will require all parties receiving your Personal Information to take appropriate measures to protect your Personal Information and to process your Personal Information only for the purposes described:
Among Ledger. We may share your Personal Information among Ledger businesses or entities depending on where you are located and the Services that you use. We use your information in accordance with this Policy, and we share this information for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services that we provide.
Our Community. Our Services include online and offline Member communities, forums, networks, and other features through which you may share information and connect with others. This includes:
Member networks, chat rooms, forums, and/or other groups available to users. Remember that anyone can read, collect, or use your postings on a network or forum or in a chat room or group and we cannot be responsible for any unauthorized third party’s use of information that you publicly disclose online.
Through creating Member profiles for Members or permitting Members to create their own profiles on member networks or forums. Typically, such a profile contains your name, the name of your company, and other information you provide or add to your profile (content, comments, photos, etc.). Depending on the Services you use, this profile might be created automatically and be accessible to other members of the network or forum. Member Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).
When we receive information about you in connection with your relationship with our Members or clients—for example, if you are a Member’s employee or if you are visiting one of our clients—we may share your information with the Member or client with which you have such a relationship, for example, by alerting the Member or client that you have arrived to visit. Ledger is not responsible for the privacy practices of our Members or clients, or their third-party service providers, including those they integrate with our Services.
We also may share information about you with others in the community to provide you with certain features. For example, if you sign up for a professional event, we may provide the event organizer with certain information about you.
Primary Members. Information on the utilization of our services by individual members may be shared with the primary member or the organization who purchased the memberships. Examples of individual Members are employees of a Member company.
Suppliers and Vendors. We rely on various third parties to perform a variety of services on our behalf and to help us grow and improve our business. We take steps to ensure that where we share your Personal Information with these third parties that they act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.
Research / Survey Solicitations. From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
Other Parties in Connection with a Corporate Transaction. We disclose or share your information if we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
Other Third-Party Partners, in Connection With your Membership Agreement. When the terms of your Membership Agreement allow, and where permitted by applicable law, we may disclose or share your contact information with select third-party partners who may contact you to offer additional services related to your Membership. You may opt out of further communications with such third-party partners by contacting Ledger and are under no obligation to meet with third-party partners or purchase additional services.
Other Third-Party Partners, With Your Consent. We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.
6. Ledger’s Use of Third-Party Content and Functionality. We 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 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 offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.
We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-Ledger related websites within their networks.
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 or the Digital Advertising Alliance, for more information about these companies use your data.
7. Your Data Rights. We value your rights to your data. In accordance with applicable law, you may have the right to:
- request confirmation of whether we store, use, or share any of your Personal Information and be informed about third parties with whom your Personal Information has been shared;
- obtain access to or a copy of your Personal Information;
- receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company;
- restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;
- seek correction of inaccurate, partial, untrue, or incomplete Personal Information; In some cases, we may provide self-service tools that enable you to update your Personal Information;
- request erasure, anonymization, or blocking of Personal Information held about you by Ledger, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
- withdraw your consent to our processing of your Personal Information. If you refrain from providing Personal Information or withdraw your consent to processing, some features of our Service may not be available;
- object to an automated decision Ledger has made and request the review of decisions taken exclusively based on automated processing if that could affect data subject rights; or
- cancel your online account if one has been created.
Additionally, you may have the right to opt-out or withdraw your consent for certain uses and disclosures of your Personal Information as outlined below.
Sensitive Personal Information. Sensitive Personal Information is data that relates to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you. You may withdraw that consent, in accordance with applicable law. Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Personal Information for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Leger will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, Ledger will comply with the law or contract.
If you would like to exercise any of these rights, please contact us at [email protected]. We will process all such requests in accordance with local laws. To protect your privacy, Ledger will take steps to verify your identity before granting access or making any changes to your Personal Information.
SENSITIVE INFORMATION. BECAUSE EMAIL COMMUNICATIONS ARE NOT ALWAYS SECURE, PLEASE DO NOT INCLUDE CREDIT CARD OR OTHER SENSITIVE PERSONAL INFORMATION (E.G., RACIAL OR ETHNIC ORIGIN, RELIGION, HEALTH, OR THE LIKE) IN YOUR EMAILS TO US.
8. Video Surveillance. Ledger’s facilities use surveillance cameras to meet our legitimate business interests in protecting the safety of Ledger’s employees, Members, guests and property. These recordings may be accessed by Ledger. We may also make video footage available to members and other third parties authorized by Ledger. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are generally retained for a limited period, but may be kept longer where Ledger determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.
9. Collection of Data from Children. Generally, our Services are not directed to children, and we do not knowingly collect Personal Information from children except as permitted under applicable law. If we become aware that a child has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.
We display advertisements and other content from third parties or partners that link to third-party websites that we do not own or operate. We provide links to these third-party sites as a convenience to you. 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. Additionally, third parties may sell goods or offer services at our facilities or in combination with our Services. We are not responsible for those third parties’ services or their privacy practices.
We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third party and not this Policy. We are not responsible for the data collection, privacy, and information sharing policies and procedures or content of such third parties.
If we make any material changes to this Policy, we will notify you of those changes by posting them on the Services or by sending you an email or other notification, as required by applicable law, and we will update the “Last Updated” date to indicate when those changes became effective.
We encourage you to review this Policy periodically to remain informed of how we use and protect your information, and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by us.