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WeWork India Privacy Policy

WeWork India Privacy Policy

WeWork India Management Private Limited along with WeWork Companies Inc. and our affiliates(collectively “WeWork India” “we,” “us,” or “our,”) cares about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how WeWork India collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), applications (“apps”), or other services that refer to or link to this Policy(collectively our “Services”).

This Policy does not apply to information that you provide to, or that is collected by, any third-party such as any brokers, any payment platforms, etc that you may use in relation to utilisation of WeWork Services. Please consult directly with such third parties regarding their privacy policy. We will act as the data controller for your Personal Information for managing the data shared by you and shall process the same to improve, provide and offer our services to you. Your Personal Information may therefore be shared with our affiliates and third parties, which may be outside the jurisdiction of India to provide you with the services that you or your Company have subscribed with us. Any Personal information so collected and shared with us shall be governed by the WeWork Companies Inc Privacy Policy which can be found on the WeWork website (wework.com/legal/privacy) and as amended from time to time, and in accordance with all applicable data protection laws.

We want to help you build a life, and not just a living, through our Services. Before you use our Services, please read this Policy in its entirety, to help you make informed decisions about your relationship with us.

1) INTRODUCTION

a. Personal Information. “Personal Information” is 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.

b. Our Services. The Services referenced in this Policy include the Services provided by WeWork India.

c. References to “you.” In this Policy, “you” means anyone who uses our Website Services.

2. INFORMATION WE COLLECT: The Personal Information that we collect, and our use of that information depends on your relationship with us and the requirements of applicable law as described below. We collect information:

a) that you provide to us directly.

b) that your company, employer, partner, authorised representative provides to us;

c) about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies

d) If you opt-in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts;

e) from third parties such as our landlords, building managers, licensees and property brokers); and

f) that we obtain from other sources, including data brokers or information service providers (ISP)

3. INFORMATION COLLECTED FROM YOU: WeWork India requests different types of Personal Information from you and your company or others, depending on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:

a) Contact Information and other Identifiers, including your name, mailing address, phone

number, email address, and other information that enables us to contact you;

b) KYC Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth;

c) Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;

d) Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;

e) Email Calendar Information, when we integrate with your corporate email calendar (e.g.,Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book;

f) 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;

g) Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit a WeWork India location. These include services such as printer or Wi-fi usage, and desk or conference room bookings;

h) Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through feedback platforms, automated chatbots, Amazon Echo, other voice assistants 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;

i) Device and Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:

j) Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address.

k) Geolocation information, such as through your mobile device’s GPS signal or WIFI signal, and information about your contacts, depending on your device settings;

l) Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, and your offline activity, including information about events you attend at WeWork India locations; and

m) Information gathered by sensors about how you use our Services, including through Spatial and People Analytics Sensors (“SPA 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.

n) Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames, relationship to emergency point of contact, vehicle 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 other community profile.

4. INFORMATION COLLECTED ABOUT YOU

o Third-Party Sources. We obtain Personal Information about you from your company, employer, partner, authorised representative OR host if you are a visitor or guest to one of our spaces. We may also 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. If we obtain Personal Information about you from a third party, we will confirm that the Personal Information is from a legitimate source.

o 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 through the use of Google Analytics is not combined with your Personal Information. We also may use other third-party analytics tools to collect similar information about use of certain online Services.

o “Do Not Track.” If you have enabled the feature, your web browser may transmit “do-nottrack” signals to our websites and other online services with which your browser communicates to our Website. In the event that you chose this option, WeWork will no longer track your information.

o Mobile Computing. We provide websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of the Services may require you to log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, WeWork enables you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices.

These tools transmit Personal Information to WeWork to enable you to access your user accounts and to enable WeWork to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

5. USE OF PERSONAL INFORMATION: In general, your Personal Information is used by us to:

a) provide you with Services, including online and offline events, and other materials you request;

b) protect against fraud, abuse, or harm and to otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);

c) respond to or fulfil customer service requests;

d) analyse, better tailor, and improve our products and Services;

e) contact you about our Services, promotions, and sweepstakes, 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, post, or by other means as communicated to you from time to time; and

f) 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.

6. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION IF RESIDENT IN THE UK AND EU

a. The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, for KYC purposes as per legal requirements and to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others with a secure environment, analyzing, improving, and better tailoring our products and Services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.

b. Subject to applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 9 of this Policy.

7. SHARING OF PERSONAL INFORMATION: We disclose your Personal Information in limited circumstances to WeWork Companies Inc, in order 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 particular 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:

a) 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.

b) 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 or students of a member university.

c) 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.

d) Landlords and Building Management. In some cases we may share your Personal Information with our landlords and/or building management at WeWork India properties so that they can effectively manage and operate the building

e) 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.

f) Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your Personal Information to other parties:

i) to provide you with the Services that you or your company request;

ii) to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;

iii) to comply with applicable law or respond to a legal process or a request for cooperation by a government entity or law enforcement;

iv) to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services; or

v) to protect our rights, property, and safety or that of any of the WeWork India companies, business partners, members, or employees;

vi) and where otherwise required by applicable law.

We share Personal Information in this way, either to comply with legal obligations to which we are subject to, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.

g) Other Parties in Connection with a Corporate Transaction. We disclose or share your information in the event that 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.

h) 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 WeWork India and are under no obligation to meet with third-party partners or purchase additional services unless expressly agreed by you.

i) 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.

8. THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES

We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:

a) 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.

b) 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.

c) Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.

d) SOCIAL MEDIA: We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and videos with the public through unaffiliated external social media sites. While we will not edit comments, we may delete a comment from our page on a social media site if it, for example, does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language, or if it is a personal attack or hate speech that targets or disparages any ethnic, racial, age, or religious group (or other legally protected group), or if it advocates illegal activity or violates copyright laws.

9. RIGHTS IN YOUR INFORMATION: ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION

We value your rights to your data. In accordance with applicable law, you may have the right to:

a) 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;

b) obtain access to or a copy of your Personal Information;

c) receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);

d) restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;

e) 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;

f) request erasure, anonymization, or blocking of Personal Information held about you by WeWork, subject to certain exceptions prescribed by law;

g) 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;

h) object to an automated decision that WeWork India has made and request the review of decisions taken exclusively based on automated processing, if that could affect data subject rights; or

i) cancel your online account if one has been created. We will process all such requests in accordance with local laws. To protect your privacy, WeWork will take steps to verify your identity before granting access or making any changes to your Personal Information. To request to review, update, or delete your personal information or to otherwise reach us, please submit a request by emailing us at privacy@wework.com

10. OPT-OUT and WITHDRAWAL OF CONSENT: You may have the right to opt-out or withdraw your consent for certain uses and disclosures of your Personal Information as set out in this Policy, and in specific circumstances, for example related to direct marketing.

11. SENSITIVE PERSONAL INFORMATION: Where you have consented to WeWork India’s use of “sensitive” Personal Information (e.g., Personal Information relating to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you) (“Sensitive Personal Information”), 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, WeWork India 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, WeWork India will comply with the law or contract.

12. EMAIL AND TELEPHONE COMMUNICATIONS

a) Opting Out of Marketing Communications. We will provide a means to unsubscribe from our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. We may also need to send you certain communications regarding the operation and administration of the Services, and you will not be able to opt-out of those communications, e.g., communications regarding updates to our Terms of Use or this Policy. If you no longer desire to be contacted by us, you must terminate your relationship with WeWork India and can no longer use our Services.

b) Collaboration. We do not sell your Personal Information to third parties for their direct marketing purposes. We may partner with other organizations to run events or programs. The Personal Information and other information that you provide to sign up or participate in that event or program will be available to that organization, and you may receive emails or other communications from it after the event. Please refer to that organization’s privacy policy for information on how to opt-out of its communications.

c) Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.

13. RETENTION: WeWork will retain your Personal Information for as long as you have a relationship with us, and for a period of seven (7) years after your relationship with us has ended to comply with applicable laws.

When determining how long this retention period will last once the purpose of processing the Personal Information has been satisfied, we take into account the length of time Personal Information is required to:

a) Continue to develop, tailor, upgrade, and improve our Services;

b) Maintain business records for analysis and/or audit purposes;

c) Comply with record retention requirements under the law;

d) Defend or bring any existing or potential legal claims; or Address any complaints regarding the Services.

14. INFORMATION SECURITY: The security of all Personal Information provided to WeWork India is important to us. WeWork India takes reasonable steps endeavoring to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while WeWork India strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials or badge with others, logging out when you leave your desk, and other security best practices.

15. AUTOMATED PROCESSING: In the future, we may use automated processes to help us determine your eligibility for new services, alternate space, or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, or request that we restrict the use of your Personal Information for the purposes of these automated decisions. By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically 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.

16. OTHER RIGHTS AND IMPORTANT INFORMATION

a) CCTV: WeWork India’s buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of WeWork India’s employees, members, vendor employees and guests and their property. These recordings may be accessed by WeWork India. WeWork India may also make CCTV footage available to members and other third parties authorized by WeWork India. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are generally retained for a limited period of time but may be kept longer where WeWork India or an applicable member determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request us to retain them.

b) THIRD PARTIES: This Privacy Policy does not address the privacy, data, services or other

practices of any entities other than WeWork India. 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.

17. CHANGES TO THIS POLICY IN THE FUTURE

Any information that is collected via the Services is covered by the Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion. 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 WeWork India.

18. COMPLAINTS AND QUESTIONS

If you have any complaints or have questions regarding this Policy, please contact us at privacy@wework.co.in or at infosec@wework.co.in

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