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Last Updated: September 13, 2023
1. INTRODUCTION
This Supplemental Privacy Notice for Colorado Residents (“Colorado Notice”) supplements the information contained in WeWork’s Global Privacy Policy and applies solely to consumers who reside in Colorado. This Colorado Notice is intended to provide you with additional information with regard to our handling of your personal data and certain consumer rights.
When we use the terms “consumer” and “personal data” in this Colorado Notice, we are using those terms as the Colorado Privacy Act (“CPA”) defines them, which the CPA generally defines a “consumer” as ‘a Colorado resident acting only in an individual or household context’ and explicitly omits individuals acting in ‘a commercial or employment context, as a job applicant, or as a beneficiary of someone acting in an employment context’ and “personal data” as ‘information that is linked or reasonably linkable to an identified or identifiable individual,’ but does not include de-identified data or publicly available information. Capitalized terms used but not defined in this Colorado Notice shall have the meaning ascribed thereto in WeWork’s Global Privacy Policy.
Please note, this Colorado Notice does not apply to personal data that we process as a processor on behalf of our customers in connection with the WeWork Workplace Platform.
2.1 Categories of Personal Data, Purpose of Processing, Categories of Personal Data Shared with Third Parties and Categories of Third Parties with Whom We Share Personal Data
In our Global Privacy Policy,
Section 3: “Personal Data We Collect” describes the categories of personal data we collect and process;
Section 5: “Purposes for Which We Process Your Personal Data and the Legal Bases on Which We Rely” describes the purposes of processing personal data; and
Section 6: “How We Share Your Personal Data” describes the categories of third parties with whom we share personal data.
Some or all of the categories of personal data we process may be shared with third parties. The categories of personal data that we share with third parties depends upon the purposes for which we process personal data. If we engage a third party in connection with any of the purposes for which we process personal data, the categories of personal data associated with that purpose will be shared with the associated third party. Please refer to Sections above in our Global Privacy Policy for more context.
2.2 Sharing of Personal Data for Targeted Advertising
As is common practice among companies that operate online, we may share limited personal data with certain third parties, including non-affiliated Advertising Partners for purposes of targeted advertising on non-WeWork websites, applications and services. In addition, we may allow certain Advertising Partners to collect personal data from our websites and services using cookies, web beacons, mobile advertising identifiers and other technologies. These Advertising Partners may use this information to display online advertisements tailored to your interests and preferences across your browsers and devices and to conduct ad campaign measurement and website analytics. Any personal data we may have shared for the purpose of targeted advertising is limited to Device, Internet & Network Activity Information. For more information on how we use cookies, targeted online advertising and other tracking technologies, please see our Cookie Policy.
2.3 De-Identified Data
We may use de-identified data in some instances (as that term is defined under CPA). We maintain and use such data without attempting to re-identify it.
3.1 Your Rights
As a Colorado consumer, you may have the rights listed below in relation to personal data that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include the right to:
Right to Opt Out: To opt out of the processing of the personal data concerning the consumer for purposes of (i) targeted advertising, (ii) the sale of personal data or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer;
Right of Access: To confirm whether or not we are processing your personal data and to access such personal data;
Right to Correction: To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
Right to Deletion: To delete personal data concerning you;
Right to Data Portability: When exercising the right to access personal data, to obtain the personal data in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance.
3.2 How to Exercise Your Rights
You may exercise your rights by completing our Privacy Webform. To protect your privacy and maintain security, we may take steps to verify your identity before complying with your request, and may decline your request if we are unable to verify your identity. To verify your identity, we may collect information such as your email address, government issued ID or date of birth, before providing a substantive response to the request.
We do not sell your personal data or engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (as those terms are defined under CPA). To opt out of targeted advertising, please refer to Section 7: “How to Manage Cookies, Targeted Online Advertising and Other Tracking Technologies?” in our Cookie Policy.
3.3 How to Appeal Our Refusal to Take Action on a Request
If we decline to take action in any request that you submit in connection with the rights described in the above sections, you may ask that we reconsider our response by sending an email to privacy@wework.com. Please use “CPA Appeal of Consumer Rights Request” in the subject line. If you have concerns about the result of the appeal, you may contact the Colorado Attorney General.
If you have questions or concerns regarding this Colorado Notice or if you have a complaint, please email us at: privacy@wework.com contact us by using the information in Section 14: “Contacting Us” in our Global Privacy Policy.