Privacy Policy

Etherea Ventures Pvt. Ltd. (“Etherea”) is committed to maintaining user’s trust by protecting user’s Personal Data. This Privacy Policy (“Policy”) describes how we collect, use, disclose and otherwise process your Personal Data both offline and on https://etherea.in (“Website”) in connection with user’s use of our website (“Website Services”). By accessing our website, you confirm that you have read, understand, and acknowledge the terms of this Privacy Policy. This Policy is applicable irrespective of whether the user uses computer, mobile phone, tablet, or television or any other media or computer resource to access our Services.

Etherea will act as the data controller of user’s Personal Data described in this Policy and any Personal Data so collected and shared with us shall be governed by this Privacy Policy which can be found on the Etherea Website as amended from time to time, and in accordance with all the applicable data protection laws.

In view of the above, it is important that you read the Privacy Policy carefully as your Personal Data will be processed in accordance with this Policy as and when you access our Website.

1.DEFINITION :
  • Personal Data: It is the data that relates to user and can either on its own or in combination with other information identify the user as an individual. Personal Data does not include data that has been aggregated or made anonymous such that the user can no longer be identified using means reasonably available to our company.
  • Our Services: The Services referenced in this Privacy Policy include the Services provided by our company “Etherea Ventures Pvt. Ltd.”
  • References to “user” includes and means any person who uses our Website for availing Services.
2.SOURCE OF INFORMATION

We understand that protection of user’s data is very important, therefore we collect the information provided by you, in accordance with law and only for the reasons set out in this Privacy Policy. We collect the information as follows:

  • The user provides to us directly or through user’s company, employer, partner, authorised representative and any permitted assigns.
  • About user devices and user’s location, and user’s use of our Services, including but not limited to cookies, pixels, web beacons, logs, and any other available resources through Internet technologies.
  • If the user opt-in to certain features or depending on user device settings, we obtain geo-location data and information about user contacts.
  • From third parties such as our landlords, building managers, licensees, and property brokers.
  • From other sources, including data brokers or information service providers (ISP).
  • 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 Data or other information that we receive from or about user, where it is necessary to provide the Services as requested by the user. If we obtain Personal Data about user from a third party, we will confirm that the Personal Data is collected from a legitimate or valid sources.
3.CONTENTS OF INFORMATION COLLECTED WHEN USERS USE WEBSITE

We request different types of Personal Data from the user depending on the Services, the user avails and user’s relationship with us. We may collect the following categories of information, depending on the Services that you use:

  • Contact Information and other Identifiers, including user’s name, mailing address, phone number, email address, and other information that enables us to contact the user.
  • KYC Verification Information, including user’s personal photograph, photo ID or government issued identification, and date of birth etc.
  • Professional and Employment-Related Information, including user’s company name, title, role, team, and other information about user’s profession.
  • Email Calendar Information, when we integrate with user’s corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding the conference rooms user books.
  • Office Preferences, including user’s requested or preferred temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences made in relation to the Services.
  • Utilization Information, including how frequently user visits, how long user stays, and what types of Services user avails when users visit a Etherea location. These include services such as printer or Wi-fi usage, and desk, seat, cabin or conference room bookings.
  • Communications, and any other information that user intentionally or unintentionally share, send, or receive while using the Services, including user’s 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 the user choose to share with us including but not limited to user’s photos, videos, blog entries, interests, hobbies, lifestyle choices, and the groups with which users are affiliated and that user send or receive using the Services;
  • Device and Usage Information, including information about user’s computer or device and Internet or other electronic network activity information.
  • Information about user’s online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, and user’s offline activity, including information about events user attend at Etherea locations.
  • Information gathered by sensors about how user avails our Services, including throughin offices, kitchens, conference rooms, and other spaces of some facilities that user may work in or visit, to promote more efficient and comfortable use of the Services. Examples of SPA Sensors include desk occupancy sensors, environmental sensors, WiFi network hubs, and optical camera-powered sensors.
  • Other Personal Data, including but not limited 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 user’s visit, photos of user, and data or files that user inputs, uploads, or stores with the Services, such as search queries that the user submits, and documents that user uploads to the Services.
  • Personal Data included in content and information that user adds to user’s member network or other community profile.
4.INFORMATION COLLECTION MECHANISM

These tools transmit Personal Data to us to enable user to access user’s accounts and to enable us to track use of these tools. Some of these tools enable user to e-mail reports and other information from the tool.

  • 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 user on the date that user visits the Website Services, other than user’s name or other identifying information which is easily available. The information collected through the use of Google Analytics is not combined with user’s Personal Data. We also may use other third-party analytics tools to collect similar information about the use of certain online Services.
  • “Do Not Track.” If users have enabled the feature, user’s web browser may transmit “do-not track” signals to our Website and other online services with which user’s browser communicates to our Website. In the event, the user choses this option, We will no longer track user’s information.
  • 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 user 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, Etherea enables user 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.
5.USE OF PERSONAL DATA:
In general, user’s Personal Data is used by us to:
  • Provide user with Services, including online and offline events and other materials as per the user’s request.
  • Protect against fraud, abuse, or harm and to otherwise provide a secure environment both physical and online environments.
  • Respond to or fulfil customer service requests.
  • Analyse, better tailor, and improve our products and Services.
  • Contact user about our Services, promotions, offers and provide user with relevant advertising, enhance users engagement with us, and otherwise communicate with user through various means, which may include by email, telephone, post, or by other means as communicated to user from time to time.
  • 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.SHARING OF PERSONAL DATA

We disclose user’s Personal Data in limited circumstances which we believe should be disclosed under need to know basis for fulfilling jobs to provide, operate, develop and improve our Services and wherever required by applicable law. Wherever required by applicable law, we only share user’s Personal Data with third parties with user’s consent. We require all parties receiving user’s Personal Data to take appropriate measures to protect user’s Personal Data and to process user’s Personal Data under confidentiality agreements only for the purposes described:

  • Our Community. Our Services include online and offline member communities, forums, networks, and other features through which user may share information and connect with others.
  • 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.
  • 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 user’s Personal Data with these third parties that they act only in line with our instructions and on our behalf, or otherwise use Personal Data in accordance with confidentiality agreements or as described in this Policy.
  • Landlords and Building Management. In some cases we may share user’s Personal Data with our landlords and/or building management so that they can effectively manage and operate the building.
  • Research/ Survey Solicitations. From time to time, we will share user’s Personal Data 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 user participates in a survey, user’s responses will be used along with other participants’ responses.
  • Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose user’s Personal Data to other parties or with the permitted assignees:
    • to provide user with the Services that user or user’s company request.
    • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants.
    • to comply with applicable law or respond to a legal process or a request for cooperation by a government entity or law enforcement agency.
    • to detect, limit, and prevent fraud, or verify and enforce compliance with the policies governing our Services.
    • to protect our rights, property, and safety or that of any of the business partners, members, or employees.
    • where otherwise required by applicable law.
  • Other Parties in Connection with a Corporate Transaction. We disclose or share user’s 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.
  • Other Third-Party Partners, in Connection With user’s Membership Agreement. When the terms of user’s Membership Agreement allow, and wherever permitted by applicable law, we may disclose or share user’s contact information with select third-party partners who may contact user to offer additional services related to user’s Membership. User may opt out of further communications with such third-party partners by contacting Etherea is under no obligation to meet with third-party partners or purchase additional services unless expressly agreed by user.
  • Other Third-Party Partners, With User’s Consent. We may request user’s consent to share Personal Data about user with certain third parties so that they can provide user with special offers, promotional materials, and other materials that may be of interest to user. With user’s consent, we also use and publicize user’s name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.
7.THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES

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

  • Third parties that provide features and functionality on the Services by means of plug-ins. Even if user do not click on or interact with social networking services or other plug-ins, they collect information about user, such as user’s IP address and the pages that user view.
  • Advertising providers help us, and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on user’s online behaviour, 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.
8.SOCIAL MEDIA:

We are active on social media (e.g., Twitter, Facebook, Instagram, Linkedin 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 like Sensitive Personal Data including (i) special categories of Personal Data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation and (ii) other Sensitive Personal Data such as criminal convictions and offences and national identification number, Excessive, inappropriate, offensive or insulting information towards individuals. We are not responsible for any information posted on the social media sites other than the information posted by its employees on its behalf.

9.RIGHT OF USER

We value user’s rights in relation to user’s data. In accordance with applicable law, user may have the right to:

  • request confirmation of whether we store, use, or share any of user’s Personal Data and be informed about third parties with whom user’s Personal Data has been shared.
  • obtain access to or a copy of user’s Personal Data.
  • receive an electronic copy of the Personal Data that user have provided to us or ask us to send that information to another company.
  • restrict our use of user’s Personal Data or, as described above, object to those uses or restrict our sharing of your Personal Data.
  • seek correction of inaccurate, partial, untrue, or incomplete Personal Data; in some cases, we may provide self-service tools that enable user to update user’s Personal Data.
  • request erasure, anonymization, or blocking of Personal Data held about user by us, subject to certain exceptions prescribed by law.
  • withdraw user’s consent to our processing of user’s Personal Data. If the user refrains from providing Personal Data or withdraw user’s consent to processing, some features of our Service may not be available.
  • object to an automated decision that Etherea has made and request the review of decisions taken exclusively based on automated processing, if that could affect data subject rights; or
  • cancel user’s online account if one has been created. We will process all such requests in accordance with local laws. To protect user’s privacy, Etherea will take steps to verify user’s identity before granting access or making any changes to user’s Personal Data. To request to review, update, or delete user’s personal data or to otherwise reach us, please submit a request by emailing us at privacy@Etherea.com.
10.OPT-OUT/ WITHDRAWAL OF CONSENT

We may obtain your express consent by clicking on a check box or signature confirming your consent for processing of Personal Data. User may have the right to opt-out or withdraw user’s consent for certain uses and disclosures of user’s Personal Data as set out in this Policy. If we possess your contact information, we may want to keep you posted about our products, services and events, through email. Should you prefer not to keep up to date with our latest information on services and receive such marketing materials, please send an email to unsubscribe-privacy@Etherea.com.

However, such withholding of information or withdrawal of consent may result in us not being able to provide services and facilities and we reserve the right to take appropriate action with respect to any obligations or in relation to any contract under which such Personal Data was sought.

We will update your preferences as soon as reasonably practicable. However, do note, if you opt out of our emailing list, as described here, we may not be able to remove your Personal Data from all our databases or other third parties. For that, you would need to raise a request to erase your data as mentioned in the above section (right of user). We may send user SMS text messages related to our Services or transactions. User can opt-out of these messages at any time by replying STOP.

11. SENSITIVE PERSONAL DATA:

Where user has consented to our use of “sensitive” Personal Data (e.g., Personal Data relating to users health, religious or philosophical beliefs, or biometric information which is used to uniquely identify user) (“Sensitive Personal Data”), user may withdraw that consent, in accordance with applicable law. Prior to disclosing Sensitive Personal Data to a third party or processing Sensitive Personal Data for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Etherea will endeavor to obtain user’s explicit consent (opt-in). Where user’s consent for the processing of Personal Data is otherwise required by law or contract, Etherea will comply with the law or contract.

12. DISCLAIMER:

We will not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the user’s account and / or information relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise. We do not store any Credit\ Debit card details. Any other personal and sensitive Personal Data shared by you, which is not asked by us during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and Etherea will not be liable for breach of such information.

13. RETENTION:

We will retain user’s Personal Data for as long as users have a relationship with us or for the purposes of record retention requirements under the law or for defending or bringing any existing or potential legal claims or address any complaints regarding the Services. On the expiry of such periods, your Personal Data will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.

14. INFORMATION SECURITY/ CONFIDENTIALITY:

The security of all Personal Data provided to Etherea is important. We take reasonable steps endeavouring to use appropriate technical or organizational measures to protect user’s Personal Data, 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. Thus, by accepting this Privacy Policy, the user accepts that transmission of Personal Data is done at your own risk. As a result, while Etherea strives to protect user’s Personal Data, we cannot ensure or warrant the security of any information that user transmits to, and user do so at user’s own risk. As such, we ask that user help us to be safer together by implementing user’s own security controls, such as a strong password, not sharing user’s credentials or badge with others, logging out when user leaves user’s desk, and other security best practices.

15. OTHER RIGHTS AND IMPORTANT INFORMATION
  • CCTV: Etherea’s buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of Etherea’s employees, members, vendor employees and guests and their property. These recordings may be accessed by Etherea. Etherea may also make CCTV footage available to members and other third parties authorized by Etherea. 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 Etherea 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.
  • THIRD PARTIES: This Privacy Policy does not address the privacy, data, services or other practices of any entities other than Etherea. 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 user. 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 user’s Personal Data prior to submitting any Personal Data. The collection, use, and disclosure of user’s Personal Data 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.
16. NO CONTRACTUAL OBLIGATION

This Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

17. INTELLECTUAL PROPERTY RIGHTS

Etherea retains all rights (including copyrights, trademarks, patents as well as any other intellectual property right) in relation to all data provided on or via this Website/applications (including all texts, graphics, and logos).

18. CHANGES IN PRIVACY POLICY

Any information that is collected via the Services is covered by the Privacy Policy in effect at the time such information is collected. We reserve the right to amend, change, modify, add, or remove the terms of this Privacy Policy at any time and at our sole discretion without providing any notification. Therefore, we encourage user to review this Policy periodically to remain informed of how we use and protect user’s information, and to be aware of any policy changes. User’s continued relationship with us after the posting or notice of any amended Policy shall constitute user’s agreement to be bound by any such changes. Any changes to this Privacy Policy shall take effect immediately after being posted or otherwise provided by Etherea.

19) USE OF SITE BY MINORS:

The minimum age for accessing the Website is 16 unless otherwise the local laws require an older age for the same. Children (under the age of 16) are not eligible to use the Site and should not submit any personal information on the Site without obtaining verifiable parental consent which includes the consent of lawful guardian.

20. COMPLAINTS AND QUESTIONS:

If user have any complaints, queries or have any questions regarding this Policy, please contact us at contact@etherea.in