Privacy policy.

Last updated: June 1st, 2023 

NEON Spaces LLC (collectively “NEON,” “we,” “us,” or “our,”) care about your privacy. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes how NEON collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites (“Website Services”), applications, or other services that refer to or link to this Policy, as well as any offline products, programs, courses, and services (collectively our “Services”). 

We want to help you connect with others and your neighborhood 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

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.

Our Services.  The Services referenced in this Policy include the Services provided by NEON. You can read more about how Personal Information is used by clicking below on the name of NEON Services, websites, or applications you use.

References to “you.”  In this Policy, “you” means anyone who uses our websites, applications, or other Services. 

Authoritative Version.  When the text of this Policy is available in multiple languages, the English version is the authoritative version, except where prohibited by applicable law.

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:

  • that you provide to us directly.

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

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

INFORMATION COLLECTED FROM YOU

NEON 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:

  • Contact Information and other Identifiers, including your name, email address, and other information that enables us to contact you;

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

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

  • Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through feedback platforms, automated chatbots or similar technology, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated — and that you send or receive using the Services;

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

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

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

INFORMATION COLLECTED ABOUT YOU

  • 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. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.

  • “Do Not Track.” If you have enabled the feature, your web browser may transmit “do-not-track” signals to our websites and other online services with which your browser communicates. We currently do not take any action in response to these signals.

  • 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, NEON 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 NEON to enable you to access your user accounts and to enable NEON to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

3. USE OF PERSONAL INFORMATION

How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:

  • provide you with our products and Services, including online and offline events, and other materials you request;

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

  • respond to or fulfill customer service requests;

  • analyze, better tailor, and improve our products and Services;

  • contact you about our Services, promotions, and 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 or by other means as communicated to you from time to time; and

  • comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

4. SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to NEON, our community, other end users, in order to provide our Services and to improve ways of working in our community and where required by applicable law. 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: 

  • Amongst NEON. We may share your Personal Information among NEON businesses or entities depending on where you are located and the Services that you use. NEON uses your information in accordance with this Policy, and we share this information for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services that we provide.

  • Our Community. Our Services include online and offline member communities, forums, networks, and other features through which you may share information and connect with others. This includes:

  • We also may share information about you with others in the community to provide you with certain features. For example, if you sign up for a in person training, we may share information about you with potential instructors.

  • Research / Survey Solicitations.  From time to time, we will share your Personal Information to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.

  • Other Parties 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:

    • to provide you with the Services that you 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;

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

    • to protect our rights, property, and safety or that of any of NEON companies, business partners, customers, or employees; and

    • where otherwise required by applicable law.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance (EDAA) to learn more. Canadian users may also visit the Digital Advertising Alliance of Canada. Further information in local languages is available at www.aboutads.info or www.youronlinechoices.eu.

4.1 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. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results.

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.

5. 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:

  1. 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;

  2. obtain access to or a copy of your Personal Information; 

  3. 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”); 

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

  5. 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;  

  6. request erasure, anonymization, or blocking of Personal Information held about you by NEON, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or noncompliant; 

  7. 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; 

  8. object to an automated decision NEON has made and request the review of decisions taken exclusively based on automated processing if that could affect data subject rights; or 

  9. cancel your online account if one has been created.   

If you would like to exercise any of these rights, please contact us at support@neon.work.

We will process all such requests in accordance with local laws. To protect your privacy, NEON will take steps to verify your identity before granting access or making any changes to your Personal Information. The California Privacy Rights section below provides additional information for California residents.

6. 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.

6.1 SENSITIVE PERSONAL INFORMATION

Where you have consented to NEON’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, NEON 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, NEON will comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

  • Opting Out of Marketing Communications.  We will provide a means to unsubscribe in 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 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 NEON and can no longer use our Services.

  • 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.

7. COMPLAINTS AND SUPERVISORY AUTHORITY

If you would like to make a complaint or if you have any questions about how we use or keep your Personal Information, you may contact NEON at support@neon.work. 

For visitors to our Services you may have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction, if you believe our processing of your Personal Information violates applicable law.

8. RETENTION

We retain the personal information we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and 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:

  • Continue to develop, tailor, upgrade, and improve our Services;

  • Maintain business records for analysis and/or audit purposes;

  • Comply with record retention requirements under the law;

  • Defend or bring any existing or potential legal claims; or

  • Address any complaints regarding the Services.

10. INFORMATION SECURITY

The security of all Personal Information provided to NEON is important to us. NEON 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. 

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.

11. OTHER RIGHTS AND IMPORTANT INFORMATION

11.1 CCTV

NEON’s buildings and facilities have CCTV installed to meet our legitimate business interests in protecting the safety of NEON’s employees, members, and guests and their property. These recordings may be accessed by NEON. NEON may also make CCTV footage available to members and other third parties authorized by NEON. 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 NEON 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.

NEON’s CCTV practices are based on an assessment of the data protection interests of affected data subjects against our legitimate interests. This may entail consideration, for example, of the likelihood and impact of unlawful or impermissible conduct on our communities and expectations of privacy in particular facilities or spaces that may be subject to CCTV. The recordings are generally retained for a limited period of time in accordance with Section 9 of this Global Privacy Policy.

11.2 COLLECTION OF INFORMATION FROM CHILDREN

Generally, our Services are not directed to children, and we do not knowingly collect Personal Information from children except as permitted under applicable law. If we become aware that a child has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.

11.3 THIRD PARTIES

This Privacy Policy does not address the privacy, data, services or other practices of any entities other than NEON, including landlords and building managers.

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     .

11.4 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 NEON.

11.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding this Policy, please contact us at support@neon.work. 

NEON will address your concerns and attempt to resolve any privacy issues in a timely manner.

Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.

Privacy Notice for California Residents

California Consumer Privacy Act

California residents have the right under the California Consumer Privacy Act (“CCPA”) to receive notice of the categories of personal information we collect, the purposes for which those categories of personal information will be used, and how we determine the length of time for which the personal information is maintained. You are also entitled to receive notice regarding how we disclose personal information and your rights under the CCPA.

Categories of personal information collected. We collect and use the following categories of personal information:

Identifiers; contact and payment information; characteristics of protected classifications under California or federal law (such as demographic information like age and gender); sensitive information; commercial information; internet or other electronic network activity information; and audio, electronic or visual information. 

Categories of sources of personal information collected. We collect the personal information described above from the following sources:

·       Directly from you

·       Automatically from your devices when you interact with us or our services or connect to our system

Purposes of collection. We collect and use your personal information for the following purposes:

·       Provide you with our products and Services, including online and offline events, and other materials you request

·       Protect against fraud, abuse, or harm and to otherwise provide a secure environment

·       Respond to or fulfill customer service requests

·       Analyze, better tailor, and improve our products and Services

·       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

·       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

Retention. We retain the personal information we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

We utilize the following criteria to determine the length of time for which we retain personal information once the purpose of processing the personal information has been satisfied:

·       The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes

·       Whether we are required to retain the information, or the information is otherwise necessary, in order to comply with legal obligations or contractual commitments, defend against potential legal claims, detect or prevent potential illegal activity or actions in violation of our policies and procedures, secure our systems and online environment, or protect health and safety

·       The privacy impact on individuals of ongoing retention

·       The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure

Disclosure of Personal Information. We disclose the categories of personal information described above for business and commercial purposes to the following categories of parties: within the NEON companies and our community; to primary members, landlords and building management, licensees, service providers; and to other parties pursuant to the terms of your membership agreement and as needed to comply with legal process or protect our services.

Sale or Sharing of Personal Information. We "sell" or "share" (as defined under California law) the following categories of personal information to advertising, marketing and analytics providers:

·       Identifiers

·       Internet or Electronic Network Activity Information

Right to Opt Out of Sale or Sharing of Personal Information. You have the right to opt out of future sales or sharing of personal information. You can exercise this right by clicking Your Privacy Choices.

Right to Know, Correct, and Request Deletion. You have the right to request that we disclose what personal information we collect, use, and sell, as well as the right to request that we delete certain personal information that we have collected from you. If we hold personal information that is not accurate, you have the right to request that we correct this information.

You or your authorized agent may submit a request to exercise your rights by emailing us at support@neon.work. For your security and to ensure unauthorized third parties do not access your personal information, we will require you to verify your identity before we can act on your request. For requests to correct inaccurate information, we may ask you to provide documentation that demonstrates why or how the existing information is inaccurate. Before accepting a request from an authorized agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us or confirm that you provided the authorized agent permission to submit the request.

We cannot 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 that relates to you.

Right to Restrict Use of Sensitive Personal Information. You have the right to request that a business limit its processing of sensitive personal information under certain circumstances. You can exercise your right by emailing us at support@neon.work

Right to Non-Discrimination. You have a right not to receive discriminatory treatment for the exercise of your privacy rights. 

Shine the Light law

California residents are entitled to request and obtain certain information about the disclosure of certain categories of their Personal Information to third parties for their direct marketing purposes. Requests may be sent to support@neon.work