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INTRODUCTION

Thank you for using Office Eats! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Office Eats. We have a dedicated privacy team that’s committed to protecting all the personal information we collect and help ensure that personal information is handled properly worldwide.

This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Office Eats Platform and the Payment Services. This privacy policy describes our privacy practices for all websites, platforms and services that link to it.

Definitions

If you see an undefined term in this Privacy Policy (such as “Listing” or “Office Eats Platform”), it has the same definition as in our Terms of Service (“Terms”).

Data Collector

When this policy mentions “Office Eats,” “we,” “us,” or “our,” it refers to Office Eats, that is responsible for your information under this Privacy Policy (the “Data Collector”).

• If your country of residence is the Canada the Data Collector is Office Eats.
• If your country of residence is the United States, the Data Collector is Office Eats. (“Office Eats”).

Applicability to Payments

This Privacy Policy also applies to the Payment Services provided to you by Office Eats pursuant to the Payment Terms of Service (“Payments Terms”). When using the Payment Services, you will be also providing your information, including personal information, to one or more Office Eats Payment entities, which will also be the Data Collector (the “Payments Data Collector”) of your information related to the Payment Services, generally depending on your country of residence.

Please see the Contact Us section below for contact details of the Data Collectors and Payments Data Collectors.

INFORMATION WE COLLECT

There are three general categories of information we collect.

Information You Give to Us.

Information that is necessary for the use of the Office Eats Platform.

We ask for and collect the following personal information about you when you use the Office Eats Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

• Account Information. When you sign up for an Office Eats Account, we require certain information such as your first name, last name, email address, and Contact Phone Number.
• Profile and Inventory Information. To use certain features of the Office Eats Platform (selling or renting items), we may ask you to provide additional information, which may include Item description, price and quantity available.
• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
• Payment Information. To use certain features of the Office Eats Platform (such as selling or renting items) we may require you to provide certain financial information (like your bank account or Paypal information) in order to facilitate the processing of payments (via Office Eats Payments).
• Communications with Office Eats and other Members or guests. When you communicate with Office Eats or use the Office Eats Platform to communicate with other Members or guests, we collect information about your communication and any information you choose to provide.

Information that is necessary for the use of the Payment Services.

The Payments Data Collector needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

• Payment Information. When you use the Payment Services, the Payments Data Collector requires certain financial information (like your bank account or valid Paypal account information) in order to process payments and comply with applicable law.
• Identity Verification and Other Information. If you are a Office Eats Host, the Payments Data Collector may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.

Information We Automatically Collect from Your Use of the Office EatsPlatform and Payment Services.

When you use the Office Eats Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Office Eats Platform and Payment Services.

• Geo-location Information. When you use certain features of the Office Eats Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Office Eats may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
• Usage Information. We collect information about your interactions with the Office Eats Platform such as the pages or content you view, your searches for Listings, purchase or rentals you have made, and other actions on the Office Eats Platform.
• Log Data and Device Information. We automatically collect log data and device information when you access and use the Office Eats Platform, even if you have not created an Office Eats Account or logged in. That information includes, among other things: details about how you’ve used the Office Eats Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Office Eats Platform.
• Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Office Eats Platform or engage others to track your behavior on our behalf.
• Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting Office Eats with a description of your request and validation information.
• Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Office Eats Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
• Payment Transaction Information. Office Eats Payments collects information related to your payment transactions through the Office Eats Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Office Eats Payments and to allow the provision of the Payment Services.

Information We Collect from Third Parties.

Office Eats may collect information, including personal information, that others provide about you when they use the Office Eats Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Office Eats Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

• Third Party Services. If you link, connect, or login to your Office Eats Account with a third-party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information. For Members in the United States, to the extent permitted by applicable laws, Office Eats may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, Office Eats may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products (such a Office Eats for work and programs with property managers and owners) may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals. If you are invited to Office Eats, the person who invited you may submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Office Eats Platform through partnerships, or about your experiences and interactions from our partner ad networks.

Children’s Data.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Office Eats Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Office Eats Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

Provide, Improve, and Develop the Office Eats Platform. We may use the personal information to provide, improve, and develop the Office Eats Platform such as to:

• enable you to access and use the Office Eats Platform,
• enable you to communicate with other Members,
• operate, protect, improve, and optimize the Office Eats Platform and experience, such as by performing analytics and conducting research,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
• to operate, protect, improve, and optimize the Office Eats Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Host Guarantee, Host Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with the Office Eats Platform, your search and purchase or rental history, your profile information and preferences, and other content you submit to the Office Eats Platform, and
• enable your use of our enterprise products.

We process this personal information for these purposes given our legitimate interest in improving the Office Eats Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to: detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, conduct security investigations and risk assessments, verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide), conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required, comply with our legal obligations, Resolve any disputes with any of our Members and enforce our agreements with third parties, enforce our Terms of Service and other policies, and in connection with the activities above, we may conduct profiling based on your interactions with the Office Eats Platform, your profile information and other content you submit to the Office Eats Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Office Eats Platform if such processes detect activity that we think poses a safety or other risk to the Office Eats Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

We process this personal information for these purposes given our legitimate interest in protecting the Office Eats Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

• send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Office Eats or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
• personalize, measure, and improve our advertising,
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Office Eats or its third-party partners,
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Office Eats Platform, information obtained from third parties, and your search and purchase or rental history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
• enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Office Eats Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Office Eats Account, and
• invite you to event and relevant opportunities (for example, when you share your Host story, we may use the information provided to reach out to you to invite you to relevant events).

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

How the Payments Data Collector uses the Personal Information Collected. We may use the personal information as a part of Payment services such as to:

• Enable you to access and use the Payment Services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Payments Data Collector processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

SHARING & DISCLOSURE

Advertising and Social Media; Sharing with Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Office Eats Account or when you participate in promotional activities conducted by Office Eats partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Office Eats Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Office Eats. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask Office Eats to cease processing your data for these direct marketing purposes by sending an e-mail to Office Eats.

Sharing between Members.

To help facilitate purchase transactions or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

• When you as a Guest submit a purchase or rental request, certain information about you is shared with the Host (and Co-Host, if applicable), including your profile, full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your purchase or rental is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
• When you as a Host (or Co-Host, if applicable) have a confirmed purchase or rental, certain information is shared with the Guest (and the additional Guests they may invite, if applicable) to coordinate the purchase or rental, such as your profile, full name, phone number, and Accommodation or Experience address.
• When you as a Guest invite additional Guests to a purchase or rent, your full name, travel dates, Host name, inventory item listing details, the Accommodation address, and other related information will be shared with each additional Guest.

We don’t share your billing and payout information with other Members.

Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Office Eats may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Office Eats, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (See more information on Office Eats Law Enforcement Guidelines ), (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Office Eats, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Office Eats Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Office Eats property, its Members and the Office Eats Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

Service Providers.

Office Eats uses a variety of third-party service providers to help us provide services related to the Office Eats Platform and the Payment Services.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Office Eats Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims (such as claims under the Office Eats Host Guarantee). These providers have limited access to your personal information to perform these tasks on our behalf and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

Office Eats and the Office Eats Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract

Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

OTHER IMPORTANT INFORMATION

Analyzing your Communications.

We may review, scan, or analyze your communications on the Office Eats Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Office Eats legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

Managing Your Information.

You may access and update some of your information through your Account settings. If you have chosen to connect your Office Eats Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up to date.

Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Office Eats Account).

Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Office Eats Account for fraud or safety reasons, we may retain certain information from that Office Eats Account to prevent that Member from opening a new Office Eats Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Office Eats and Office Eats Payments may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Office Eats Platform, even after your Office Eats Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Office Eats Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Withdrawing Consent and Restriction of Processing.

If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Office Eats specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Office Eats override your own.

Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Office Eats and Office Eats Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Office Eats and/or Office Eats Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Office Eats to cease processing your data for these direct marketing purposes by sending an e-mail to Office Eats.

Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.

SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Office Eats Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Office Eats Account, please contact us following the instructions in the Contact Us section below.

CHANGES TO THIS PRIVACY POLICY

Office Eats reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Office Eats Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Office Eats Platform will be subject to the revised Privacy Policy.

CONTACT US

If you have any questions or complaints about this Privacy Policy or Office Eats information handling practices, you may email us at the email addresses provided in the home page.

Last Updated: August 4, 2024