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The Great Room by Industrious

Privacy Policy

At The Great Room ("TGR"), we want you to know that we value your personal information and that we respect your privacy. This Privacy Policy applies to users of our Site (as defined below). It explains our online information practices and the choices you can make about the way your personally identifiable information is used on our Site. Our Privacy Policy explains how TGR collects, uses, maintains and discloses information that it collects from the Site. TGR's "Terms of Use" are available on our website. Please read our Privacy Policy for more information.

1. Definitions

A. "You" and "your" mean the individual or entity visiting or using the Site.

B. "TGR", "we," "us" and "our" means TGR.

C. "Site" refers to TGR's website applications maintained by TGR.

D. "Non-Personal Information" is any information that is not Personally Identifiable Information (defined below). Non-Personal Information includes, without limitation, Personally Identifiable Information that has been anonymized.

E. "Personally Identifiable Information" or "PII" is non-public information we receive from your use of the Site that can be used, alone or in combination with other information in our possession, to identify a particular person/individual. It may include information such as name, address, telephone number and other personal information you provide us or that we collect about you.

F. "Data" includes both Non-Personal Information and Personally Identifiable Information.

2. Information Collected and Consent

You do not have to provide any Personally Identifiable Information to browse the publicly available pages of the Site, though certain information is collected automatically when you visit the site, as described under "Information We Automatically Collect". However, in order to obtain or use products or services that are or may be provided on or through the Site or that we may otherwise offer online or offline (collectively, the "Services") you may be required to register and provide Personally Identifiable Information. We collect some or all of the following categories of information:

a. Information You Provide Us:

We may collect your first and last name, title, date of birth, age, gender, mailing address and post code, geographic area, billing address, phone number (landline and/or cellular), occupation, payment information, email address, company, and job title. In certain circumstances we collect copies of government identifications or other identity documents including your driver's license, we may also collect additional information from you depending on the nature of the transaction, such as information concerning your business and financial information related to your business and/or you. We also collect your username and password for access to the Site. We collect information from you when you (i) register on the Site, (ii) fill out forms or fields on the Site, (iii) complete an application for a product or service available through the Site, (iv) use the Site or authorize us to access any financial information stored or processed by a third party, or (v) provide us with PII or other information via the Site.

b. Information We Automatically Collect:

TGR collects certain information about you automatically when you visit the Site, communicate through the Site, or use any of our online Services. We automatically receive certain information from your browser or mobile device, such as your browser type, the operating system of your device, the URL of the site from which you came and the URL of the site you visit when leaving the Site or any of our online Services, the equipment you use to access the Site, the unique identifier of your mobile device and your activities on the Site, such as the webpages you view and how you interact with those webpages. We also receive your IP address and the name of your internet service provider ("ISP") or your mobile carrier. Depending on your device's settings, we may also receive location data and other types of information sent from third-party services or GPS-enabled devices. As you use the Site or any of our online Services, we also collect information about such usage and your actions on the Site, such as pages you viewed, access times, and how long you spent on a page. We use cookies to collect such information, as described in more detail below. We collect information on your transaction history, including products or services purchased, obtained or considered, and your purchasing or consuming history or tendencies. We use inferences drawn from this PII to create a profile about you.

c. Information Provided by Third Parties:

TGR also collects PII from sources that you have authorized to share with us or that you have authorized us to obtain information from. These include your financial institution when you make a payment through the Site. We will use your PII in those circumstances to provide the Services that your PII was shared with us to fulfill. If you believe TGR received your PII from a source without authority to share your PII with us, please contact us so that we can resolve your complaint. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you. By providing PII belonging to another person, you expressly represent and warrant that you have the authority and right to do so, and that you obtained all appropriate and required consents. SMS opt-in and mobile numbers are never collected through third parties.

3. How We Use Your Information

TGR uses PII for the following purposes:

To improve customer service:

Your information helps us to more effectively communicate with you, respond to inquiries, and to respond to your customer service requests and support needs. These may include dealing with any enquiries or issues you have about how we collect, store and use your PII, or any requests made by you for a copy of the information we hold about you.

To personalize user experience:

We use information in the aggregate to understand how our users as a group use the Services and resources provided on the Site.

To improve the Site:

We continually strive to improve our Site and the Services based on the information and feedback we receive from you.

To provide products or services and to process transactions:

Except as otherwise expressly provided in this Privacy Policy, we will use PII only for the purpose of fulfilling our duties and providing the Services. TGR may use Non-Personal Information for product development, research, or other purposes. We may use the information that you provide about yourself or that you have provided to third parties for the purpose of providing and fulfilling the Services. We do not share this information with outside parties except to the extent necessary to provide the Services. Only TGR, its subsidiaries, its suppliers and contractors involved in providing the product or service will have access to your PII. Our subsidiaries, suppliers and contractors will be required to use any PII we provide to them only for that intended purpose and subject to the terms of this Privacy Policy.

To send periodic emails:

The email address you provide for the Services will only be used to send you information and updates pertaining to the Services requested. It may also be used to respond to your inquiries, and/or other requests or questions submitted via the Site.

To develop new products or services:

TGR uses your PII and Non-Personal Information for research and commercial purposes. The information we collect may be used to develop new products or services. Except as otherwise provided in this Privacy Policy, we may use your PII and Non-Personal Information internally or, among other things, to offer our own or third party products and services. Only TGR, its subsidiaries, its suppliers and contractors involved in distributing the new product or service will have access to your PII. Our subsidiaries, suppliers and contractors will be required to use any PII we provide to them only for that intended purpose and subject to the terms of this Privacy Policy.

Fulfillment of Obligations:

Comply with contractual obligations, relevant industry standards and our policies.

Security:

Mitigate fraud, enhance the security of the Site and manage institutional risk.

For marketing:

Except as otherwise expressly provided for in this Privacy Policy or except as prohibited by applicable law, TGR may use your PII and Non-Personal Information to enhance its networking, marketing, social, and recruiting activities, and for other similar business purposes. We may also use Personally Identifiable Information to provide you information regarding new products or services. Personally Identifiable Information is not shared with entities outside of TGR other than service providers who assist us in carrying out these business functions.

Compliance with applicable law:

We may disclose your PII as we may in our sole discretion determine is necessary or reasonably required to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use, or to protect our rights, property or safety, or the rights, property or safety of others.

Change in the Site Ownership:

If ownership of the Site or of TGR changes, whether in whole or in part, information collected through the Site and the Services about you may be transferred to the new owner of the Site and/or TGR, as the case may be, and any Services can continue. In that case, your user information would remain subject to the terms and conditions of the applicable version of the Privacy Policy.

Internal administration:

We collect, use and store PII for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.

We may convert PII into Non-Personal Information by excluding information that is personally identifiable. You acknowledge that Non-Personal Information and PII that is converted into Non-Personal Information belongs to TGR and that TGR has the right to use such general information as it determines in its sole discretion. Notwithstanding the foregoing, TGR will treat as PII any item that, either alone or together with other information, we could use to identify an individual. Except as described above, we will not share with third-parties any PII without your permission.

4. Web Browser Cookies

The Site or our online Services may send a "cookie" to your computer. A cookie is a small piece of data sent to your browser from a web server and stored on your computer's hard drive. A cookie cannot read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. Cookies allow us to recognize you as a user when you return to the Site or use the online Services using the same computer and web browser. We use cookies to identify which areas of the Site or online Services you have visited. We also may use this information to better personalize the content you see on the Site or online Services.

TGR does not store unencrypted Personally Identifiable Information in the cookies. We also do not link Non-Personal Information from cookies to your Personally Identifiable Information. To help us optimize the Site or for marketing purposes, we may allow other authorized third parties to place or recognize unique cookies on your browser. Any information provided to third parties through cookies will be for enhancing your user experience by providing more relevant marketing.

Google Tag Manager

Third party services and tools we use, which may send cookies to users of the Site and may collect information from users, includes Google Tag Manager (referred to as "Google"): Google collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), Device ID (EU PII), PII (name, address, phone number, email address, login, EU-IP address, EU-unique device ID), sensitive (financial information). Aggregate data, anonymous data, PII data and sensitive data is shared by Google with third parties.

We use the information we get from Google only to improve this website and for marketing purposes. Google collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. You can review Google's privacy policy at https://www.google.com/policies/privacy/. Although Google plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google about your visits to this website is restricted by the Google Terms of Use and the Google Privacy Policy.

You can prevent Google from recognizing you on return visits to the website by disabling cookies on your browser (see below). Some browsers may allow you to manage the storage of cookies on your device. If supported by your browser, you may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert you when a cookie is placed. However, if you select these settings, you may be unable to access certain parts of the Site or the online Services. Unless you have adjusted your browser setting to refuse cookies, the Site and online Services will issue cookies.

For more information about how to manage your cookies preferences, use the 'help' menu of your web browser or explore the customer support sections of your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for your browser for instructions. Here are links to some browsers' websites:

5. Security

We will use commercially reasonable methods to keep PII securely in our files and systems.

6. Do Not Track

Your browser may provide you with the option to send a "Do Not Track" signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, the Site is not programmed to recognize Do Not Track signals, so the Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.

7. Links to Other Sites

The Site and the online Services may contain links to other websites. TGR is not responsible for the actions, practices, or content of websites linked to or from the Site or the online Services. You understand such websites may require you to agree to their terms of use and that we have no control over these terms. As always, you understand it is your responsibility to verify your legal use of a website, and use of information from the website with the corresponding website owner.

8. Compliance Notice

TGR fully complies with the relevant legislation. You can always opt out of receipt of further email correspondence from us by contacting us at [email protected].

Categories of Sources of Personal Information

TGR collects information from the following categories of sources:

  • Directly from you. For example, information you provide us directly during a telephone call, filling out an offline form or questionnaire, or providing information online through the Site.
  • From third parties. For example, information you provide to your financial institution or information gathered by a financial institution based upon your transactions with TGR.

How We Share Your Personal Information

TGR shares information in each of the above categories as follows:

  • We will share information in all of the above categories if our company is sold or we engage in a merger or other such transaction.
  • We will share information in all of the above categories of information in connection with a law enforcement request that is compliant with the relevant data privacy legislations.
  • We share identifiers with service providers who use that information only to provide services to us or that we utilize the services of to provide you with products or services, communicating with you, analyzing website use, processing payments and processing data related to the products and services we provide you.
  • We share commercial information with data analytics providers.
  • We share internet or other electronic network activity information with data analytics providers.

How We Retain and Store Your Personal Information

TGR retains your personal information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage.

Requests to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the prior 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • The business or commercial purpose for collecting or selling your personal information.
  • The categories of third parties with whom we share your personal information.
  • The specific pieces of personal information we have collected about you.
  • If we sold or disclosed your personal information for a business purpose, which we will not, two separate lists disclosing sales and disclosures.

Requests to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies, which we will disclose to you.

We are not required to grant your deletion request if retaining the personal information is necessary for us or our service providers to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impact existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided for by law.
  • Comply with the relevant data privacy legislations.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest when the deletion of the public information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
  • For solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Internally make otherwise lawful uses of your personal information that are compatible with the context in which you provided the personal information.

How to Submit a Request to Know or a Request to Delete

To request this information, please submit a verifiable consumer request to us by email at [email protected]

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We are not required to provide you with personal information more than twice in a 12-month period. TGR will not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

TGR will try to respond to your request within forty-five (45) days of receipt of your written request. If we require more time (up to 90 days), we will inform you of the extension period in writing. We will deliver our written response by mail or electronically, at your option.

How to Submit an Opt-Out Request

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at [email protected]. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sharing with third parties. However, you may change your mind and opt back in to personal information sharing with third parties at any time by emailing us. We will only use personal information provided in an opt-out request to review and comply with the request. We will act upon your opt-out request within 15 days of receipt.

9. Privacy Information for EU and UK Residents

This section supplements the information contained above in our general privacy policy and applies solely to all visitors and users of our Site who reside in the United Kingdom and the European Union. TGR is the controller of your PII, and is responsible for your PII.

Cookies

Some pages on our Site use cookies, which are small files placed on your internet browser when you visit our Site. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Where we use cookies on our Site, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our Site. For detailed information on the cookies we use and the purposes for which we use them, please refer to our the section above entitled "Web Browser Cookies".

Legal Basis for Use of Your PII

We consider that the legal bases for using your PII as set out in this privacy policy are as follows:

  • Our use of your PII is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us, to comply with the terms of use of our Site which you accept by browsing our Site and/or to comply with our contract to provide services to you); or
  • Our use of your PII is necessary for complying with our legal obligations (for example, for health and safety purposes); or
  • Where neither (a) nor (b) apply, use of your PII is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website).

Our legitimate interests are to:

  • Run, grow and develop our business (as well as the businesses of our group companies)
  • Operate our Site;
  • Carry out marketing, market research and business development;
  • Evaluate and improve our Site and Services provision; and
  • For internal group administrative purposes.

How and Why We Share Your PII with Others

We may share your PII with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We will share your PII with the following third parties or categories of third parties:

  • Our group companies, suppliers and contractors to the extent necessary to fulfil our duties to you and to provide the Services to you;
  • Service providers who assist us with business functions including networking, marketing, social, recruitment activities, data analytics (including analysing use of the Site), processing payments. SMS opt-in consent data and mobile information are never shared with or sold to third parties for their direct marketing and promotional purposes;
  • Technology or equipment providers;
  • Third-party legal counsel; and
  • Consultants or auditors.

International Data Transfers

In order to provide you with the TGR services, we may transfer your personal data to the United States or other countries. These countries' privacy laws may be different from those in your home country and may not provide the same level of data protection. For example, governmental or regulatory authorities may have wider rights of access to your personal data and you may not be able to seek details or challenge their access or exercise any other right as may apply in your country of origin.

Your Privacy Rights

You have the following rights:

  • The right to request access to your data;
  • The right to request a copy of your data in a portable format;
  • The right to request the correction of data we hold about you;
  • The right to request that we erase your data;
  • The right to request restriction of the processing of your data;
  • The right to object to our processing of your data; and
  • Where we process data based on your consent, the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at [email protected]. You also have the right to file a complaint with the applicable data protection authority.

10. Amendments

TGR reserves the right to change the Privacy Policy from time to time at its sole discretion with or without notice. Any revisions are effective immediately once posted on the Site. Your continued use of the Site shall indicate your acceptance of the revision. Revisions to the Privacy Policy regarding the use of Personally Identifiable Information are not retroactive.

11. Contact

If you have any questions about the Privacy Policy, or to report a violation of the Terms of Use, please contact us at [email protected].