and Notice of Personal Information Collection
Last Updated: December 22, 2022
2. Collection of Personal Information
3. Use of Personal Information
4. Disclosure of Personal Information
5. Your Privacy Rights
6. Additional Notices
8. Information Security
10. Contact Us
2. Collection of Personal Information
Types of Information We May Collect
When you visit our Site or use our Services, including visiting our facilities, we may collect the following types of personal information about you:
Identifiers, such as your name, email address, address, IP address, account information, unique online identifiers, social media account identifiers, driver’s license, passport, or government ID information and your image.
Additional Customer Record information, such as your signature, physical characteristics or description to the extent contained in your image (captured via an interactive webinar or at building entry), your telephone number, account passwords, and/or your payment information.
Characteristics of Protected Classifications under law, such as any information you may provide us about a disability relevant to accessing or working in our facilities.
Commercial Information, such as records of services or products you requested, obtained, or considered.
Internet or other network activity information, including online browsing or search history, authentication of passwords or online IDs for subscription access, or information about your interaction with our Digital RakuNest Service, website or any webinar.
Information and files you post, upload, create, or share when you use or access communications platforms made available for your use by RakuNest as part of our Services (e.g., Slack).
Health or Biometric Information, to the extent we conduct temperature or other physical checks, health evaluations or require proof of vaccination status or COVID test results as required to enter our facilities in California to access certain RakuNest co-working space.
Sources of Collection
We may collect the above types of information in various ways, as described below:
Information You Provide to Us Directly
We collect information you provide directly to us, such as when you fill out a form, or otherwise submit, send, or provide your information to us or our agents yourself, including when you post information, comments, or files to communications platforms made available and monitored by RakuNest.
Automatically Collected Information
When you access or use our Site or attend an online presentation or webinar, we (or our service providers) use data collection technologies to automatically collect certain information about you from the device you use to access our Site or webinar, including:
Log and Device Information: We systematically collect standard information related to your access to and use of our Site and the device you used to access the Site, such as the type and version of your browser and operating system, hardware model, mobile network information, access times and dates, pages viewed, the referrer page from which you linked to our Site, and IP address.
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) may also use technologies like cookies (small data files related to your Site visit that are stored on your hard drive or in device memory) and web beacons (embedded electronic images that help deliver cookies and detect or measure events) to automatically collect information related to your Site visit. Some collected information is considered strictly necessary to the operation of the Site and some enhance the Site performance or capture information for analytics about Site use and marketing campaign effectiveness. You can clear most cookies in your browser settings to eliminate previously collected or stored information. We do not enable third parties to set marketing cookies from our Site in a way that would constitute a “sale” or "sharing" of information to them under applicable privacy laws.
3. Use of Personal Information
We may use the information we collect about you for the business purposes listed below:
A. To Provide Our Services
We use your information to provide you with our co-working space and subscription Services. For example, we use your name and email address to manage and maintain your Account with us, your identification information to grant you access to the subscription content and facilities, and your payment information to facilitate payment for the Services. We also collect your email address and any other information you provide when you register to view or attend our free online webinars.
B. To Communicate with You/Provide Customer Service
We may contact you directly or through our service providers regarding our Services in order to deliver transactional or service-related communications. We also use your information in order to respond appropriately to your inquiries, complaints, or requests in relation to the Site or our Services.
C. To Market to You
We may use your information to send you marketing communications about the Services, and other products, services, and information that may be of interest to you. We may also use your personal information allow our third-party partners to market their products and services to you when we feel this may be of interest to you. See Sections 5(B) and 6(B), respectively, for more information about how to opt-out of sharing your information with our partners for this purpose or how to unsubscribe from our direct marketing communications at any time.
D. For Our Promotional Purposes
We may use feedback that you provide about our Services or your image captured as part of our interactive Webinars or in-person Services for our own promotional purposes, as described in our Terms of Service.
E. Site and Services Improvement, Analytics
We use your information for our everyday business operations such as analysis, administration, and improvement of the Site and Services, including to add new elements to the Services provided by third parties. We may also use your information for other internal business purposes including business analytics and strategic planning.
F. To Protect You, Others and Our Business
We may use collected information to limit spam, malware, and other malicious online activities and security risks, and to improve and enforce our security measures. We may also use your information to identify, investigate, mitigate, and help prevent illicit, illegal, fraudulent or dangerous activities or situations in relation to the Site or our facilities or Services, or otherwise as necessary to protect the safety, security, and legal rights of persons and/or Rakuten Americas and our workplaces, or to enforce our agreements or policies.
We do not process, use, or disclose sensitive personal information to infer characteristics about you.
4. Disclosure of Personal Information
A. Disclosure to Service Providers
We may disclose your personal information as necessary to vendors and service providers that perform services for us, including business operations-related services such as providing us with IT services and event registration services, providing services to maintain and control access to our co-working spaces, and supporting our provision of our Digital RakuNest Services and other add-on Services to you.
B. Sale to Third Parties/”Shine the Light” Disclosure
Privacy laws define the “sale” of personal information as an exchange of personal information for something of value, whether that is monetary compensation or other business value. Subject to your right to opt-out, we “sell” your personal data to certain of our partners by making it available to them to collect and use to market their products and services to you, including for their direct marketing purposes, in exchange for certain other benefits and information they provide to be included as part of our Services. You may opt-out of this data sale or disclosure as provided in Section 5(B), below.
C. At Your Direction
We may disclose your personal information in the event you direct us to provide it to a third-party service provider with whom we provide a referral at your request, or in the event you elect to intentionally interact with a third-party service provider through us.
D. To Comply with Law
We may disclose your personal information in response to an official request for such information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
E. To Protect You, RakuNest, or Others
We may disclose your personal information to relevant authorities if we believe you may be in danger, your actions are inconsistent with our user agreements or policies, there are reasonable indications you have violated the law, or to protect the rights, property, and safety of you, RakuNest, or others.
F. In Connection with a Business Transaction
We may disclose your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
In addition to the above listed disclosures of personal information, we may also disclose aggregated or de-identified information that cannot reasonably be used by the recipients to identify you. We maintain this type of information in a deidentified manner and do not attempt to re-identify it.
5. YOUR CALIFORNIA PRIVACY RIGHTS
Consumers residing in certain locations are afforded certain additional rights with respect to their personal information , including the following:
A. Description of Your Privacy-Related Rights
Right to Know and Access: You have the right to request that we provide certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Privacy Rights below), 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.
Our business or commercial purposes for collecting or selling that personal information.
The categories of third parties to whom we disclose that personal information.
The categories of personal information sold to each category of recipient.
The categories of personal information disclosed for a business purpose to each category of recipient.
The specific pieces of personal information we collect and hold about you (also called a data portability request).
Right to Request Deletion: You have the right to request that we delete any personal information we have 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.
Right to Correct Inaccurate Personal Information: You have the right to request that we correct personal information we maintain about you that is factually inaccurate or incomplete. Once we receive and confirm your verifiable consumer request, we will correct your personal information in our records, subject to certain exceptions.
Right to Opt-Out of Sale of the sales of Personal Information:
You have the right to opt out of disclosures of your personal information to third parties that constitute “selling” under applicable privacy laws. You may opt-out of these disclosures by clicking this link:
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. In response to you exercising any of your privacy rights, we will not:
Deny you goods or services
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
provide you a different level or quality of goods or services, or
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
because you request to know, access, or delete your personal information or opt out of its sale.
B. How To Exercise Your Privacy Rights
You may update and correct certain account information you provide to us at any time by emailing us at email@example.com.
Otherwise, to exercise your privacy rights as described above, you may submit a request to us by either:
Filling out this CCPA request webform
Contacting us by email at this address: firstname.lastname@example.org
Calling us toll-free at +1 (888) 551-2118 (privacy requests only)
You may only make a request to know or access your personal information twice within a 12-month period.
Your request must be verifiable. In order for us to verify your identity, we will match certain information that you provide in your request with data that we maintain and have determined to be reliable for the purposes of verification. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that the you are the consumer whose personal information is the subject of the request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We may require any agent making a request on your behalf to provide a written permission from you to submit a request on your behalf and will still require you to verify your identity as the requestor.
6. ADDITIONAL NOTICES
A. Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. As disclosed above, we may share your information with certain of our third-party partners for their direct marketing purposes, and you can opt-out of such sharing as provided in Section 5(B), above.
B. Notice Regarding Information of Minors
Our Site and Services are intended for adults over 16 years of age, and we do not knowingly collect, sell, or share personal information of minors under 16 years of age without affirmative authorization or affirmative, verifiable consent from a parent for those under age 13.
C. Your Other Communications Choices
If you wish to delete or deactivate your Account, please email us at email@example.com, but note that we may retain certain information or archived copies of information about you for a certain period of time as permitted or required by law or for legitimate business purposes.
Communications from RakuNest
If you no longer wish to receive any marketing-related emails sent to you by RakuNest, you may contact us at firstname.lastname@example.org. Please note that even if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your Account or the Services.
We retain personal information about you for as long as it is necessary to fulfill the purposes for which we collect it, as described above in Section 3. Some of your information may be retained in our systems even after you request your information to be deleted, in accordance with applicable privacy laws, including in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, undertake any investigations necessitated by the foregoing, and otherwise use internally in a lawful manner that is reasonably aligned with reasonable consumer expectations or compatible with the context in which the information was provided.
8. INFORMATION SECURITY
We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.
10. CONTACT US
Rakuten USA, Inc. d/b/a Rakuten Americas
RE: RakuNest Privacy
900 Concar Drive,
San Mateo, California 94402, U.S.A
Tel: +1 (888) 551-2118 (privacy inquiries only)