Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how we, Mindspace Ltd. (“Mindspace”, “we”, “our” or “us”), use Personal Information (as defined below) that we collect, receive and store about individuals in connection with the use of: (i) the Mindspace facilities and services at the Mindspace facility locations, (ii) the Mindspace mobile application, website  http://mindspace.me, and any other website, mobile application and/or digital service (on any media) that we operate (each, together with its sub-domains, content and services, a “Site”); (iii) Services on the Sites that require registration in order to join Mindspace and/or receive a Service and/or benefits as specified on the Site and (iv) any other software application that we use and/or license (each individually, and collectively, the “Software”). The Mindspace facilities, services, Sites and Software are individually and collectively referred to herein as the “Services”.

1. Introduction. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. Our way of doing that is to let you know in clear, prominent, and easily accessible way how we collect, use and share your Personal Information. In addition, this Privacy Policy explains our information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, date of birth, gender, a picture, an email address, a phone number, a home or other physical address or other contact information, a position and/or an employer, profile on a social network.

2. Terms of Use. This Privacy Policy forms part of our Mindspace End User Terms of Service which can be viewed from within the Service and which you must accept prior to downloading, installing and/or using the Services for the first time (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

3.  Consent and Modification. We further develop the Software and Services on an ongoing basis in order to be able to always provide you better service. We will update and adjust this Privacy Policy accordingly if and to the extent necessary.

We will inform you of any modifications of this Privacy Policy. Should we require further consent from you regarding our handling of your data, we will obtain your consent before any corresponding changes become effective.

You can retrieve the current version of the Privacy Policy at any time at http://mindspace.me/privacy-de/.

4.  What Personal Information We Collect and How We Collect It. We do not currently require you to provide Personal Information in order to have access to some general information available on the Services. But, we do receive and/or collect Personal Information from you in the following ways:

  1.  Membership and/or Registration for Use of Services. Some of the Services require registration. Upon registration, you will be asked to provide personal details such as first name and surname, date of birth, gender, home address, e-mail address and telephone number. The mandatory fields will be explicitly marked. Certain Services, for example reservation of facility services, community benefits and membership, may not be used without providing the information requested in the mandatory fields. Upon performance of actions through, or use of, the Services, the personal details that you provided will be recorded. You are required to provide correct, accurate and full details and, by the fact of use of the Services, confirm the validity of the details provided. It is clarified that erroneous or incomplete details may preclude you from using the Services or interrupt the use thereof, including prevention of the possibility of using the physical facilities. No personal details of a third party shall be provided without his/her explicit consent.
  2. Usernames and Passwords. Where you are asked to choose a username and password, you are required to keep them confidential in order to prevent misuse thereof.
  3. Account. In order to utilize or benefit from certain Services, you may be required to create an account (“Account”). The information you provide in the course of creating an Account or registering for an event or use of the Services, including but not limited to, name, email address, phone number, physical address, and employer, may be provided to and maintained by third parties (based on a data processing agreement between such third parties and us) offering services or Software to Mindspace and its community members, whether or not you complete the registration process, and may be used by Mindspace or its service providers in connection with the products, services and events offered by them. We may offer different options to create an Account, including:
    1. Online Registration Form: You may choose to complete and submit an online registration form. You will be asked to provide us with certain mandatory information such as your name, telephone number and email address, position and organization name, and a password that you will use for your Account. You may choose to provide optional information, such as your age and gender.
    2. Third Party Accounts: You may choose to create an Account by clicking on a ‘connect’ or ‘sign-in’ button that we may display on the Services for a designated third party website or service (each a “Third Party Account”), including but not limited to Google, LinkedIn, Facebook or Twitter. Doing so will enable you to link your Account and your Third Party Account. If you choose this option, then you will be required to approve the connection as well as the provision of information (which may include Personal Information, such as your profile picture, gender, birthdate, headline, summary, friends’ lists, previous positions and organizations), that we will obtain from your Third Party Account.
  4. ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form, or by sending an email, you may be required to provide us with certain information, such as your name, phone number and email address.
  5. Actions on or Through the Services; Device Data. When you use or install certain Services, we may collect information about your laptop, mobile device or other digital device, applications, and user identification numbers, subject to your consent as required by applicable law, depending on the type and purpose of the information to be collected. Such information may include your device type, device ID, installed applications, and date and time stamps of Services use. In addition, we may deploy tracking technologies within the Software to help us gather different statistics, and track your use of the Services including your views, clicks, form submissions, time spent using or accessing the Services, etc.
  6. Share with Friends Service. The Services may enable you to invite your friends to use our Services by sending them an invitation email, text message, or message on social media. You may do so by: (i) using the Services to send or post an invitation message via your Third Party Account and/or (ii) using the Services to send an invitation to your friend’s external email address or phone number. If you send or post an invitation message, we may collect Personal Information about the recipient such as their email address or their Third Party Account. To protect the recipient’s privacy, we provide this service subject to the Terms, and enable recipients to opt-out.
  7. Location Data. We may provide certain location-based services (“Location Services”) in connection with the Services that are dependent on data related to the geographic location of your laptop, mobile device, or other digital device on which the Software is used or installed (“Location Data”). Specifically, we may obtain GPS coordinates and IP addresses as part of the Location Data. You agree that we may collect or obtain your Location Data if the use of respective Services is subject to obtaining your Location Data. You should be able to use the settings on your device to turn off most location-sharing features. The .
  8. Profile. Some parts of the Services may enable you to build a public profile in connection with your Account (“Public Profile”). Your Public Profile will include your name and other information that you choose to include in your Public Profile, such as your gender, birthdate, profile picture and custom texts, and you may control which such information will appear on your Public Profile.
  9. Purchases. The Services may include the option to purchase Services from us or other third parties offering products and services through our Services. If you choose to make a purchase we will require sufficient information from you to complete the transaction. Such information could include a credit card number or other payment means, your name, mailing address and billing address, and related account and billing information, invoice related information, and other data required to process the order. We may also update such data should you grant us permission to bill you or your credit card or other payment means for recurring charges, such as monthly or other periodic payments. We may use the tools, software or services of third-party service providers to process transactions on our behalf, in which case you acknowledge and agree to our disclosure and transmission of information required to process the transactions and you agree to review and be bound by the terms of use and privacy policy of said third-party service providers.

5.  Events; Visits to Mindspace Facilities. When you participate in Mindspace events or visit our facilities, we may collect your name, position, email, and phone number, as well as members and companies you are visiting, subject to your consent as required by applicable law, depending on the type and purpose of information to be collected.

6. Log Files. We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, viewed pages, clicked links, and any other information your device, application, and/or browser may send to us. We may use such information to personalize your experience when using our Services, analyze trends, administer the Services, track your use of the Services, and gather demographic information, and analyze security aspects.

7. Cookies and Other Tracking Technologies. Our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

8. Publicly Available Information. Your Public Profile and any publicly available content that you post on or via the Services (“User Submissions”) may be publicly available to other users of the Services, and may also be accessed and used by people off the Services. For instance, if you ‘like’ a certain event within the Services, such information can be viewed by others. If you publish your contact information in any User Submissions or as part of your Public Profile, you may receive unsolicited messages from other users of the Services or others. We therefore encourage you to only post information that you are sure you want to be accessible to anyone.

9. The Way We Use Personal Information. If you submit and/or we collect Personal Information through the Services, then we may use such Personal Information in the following ways:

  1. We will use your Personal Information to provide, personalize and improve our Services, to provide you with support and assistance in using the Services, to solicit feedback in connection with your use of the Services, to contact you in connection with the Services and certain programs or offerings that you may have registered for, to identify and authenticate your access to the parts of the Services that you are authorized to access, and subject to your consent, to display your Public Profile to other users of our Services, to develop audience insights and/or look-alike models in connection with marketing campaigns, and target advertisements and other content to you or others, subject to applicable law.
  2. Push Notifications. We may choose to send you push notifications on your mobile device from time-to-time in order to update you about any events or promotions or other relevant information. If you no longer wish to receive these types of communications, you may turn them off at the device level.
  3. We may use your designated email address and/or phone number to: (i) send you updates or news regarding the Services and our notifications; (ii) respond to a “Contact Us” or administrative request (for example, to change your password); (iii) send you suggestions for events, benefits and other offerings; and/or (iv) send you ads and related content and information for marketing or promotional purposes. As further described in the section on Opting Out, you may choose not to receive promotional, advertising or other Services-related emails from us.
  4. If you choose to send your friend an invitation email or message we will use the contact information that you provide, or make available, to automatically send your friend an invitation email or message. Your name and email address may be included in the invitation email or message.
  5. We may share your Personal Information, Anonymous Information (as defined below) and other statistical and analytical information for the purpose of providing you with the Services. Such information may be transferred to different countries that are within the EEA, that the European Commission has deemed as providing adequate protection of personal data, or that are parties to the EU-US Privacy Shield. We will require that the recipient of the information agree to process such information in compliance with our Privacy Policy.
  6. We may transfer your Personal Information to our subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to different countries that are within the EEA, that the European Commission has deemed as providing adequate protection of personal data, or that are parties to the EU-US Privacy Shield. We require that these parties agree to process such information in compliance with our Privacy Policy.
  7. We may share your Personal Information with our third party service providers and partners, to provide you with Services and to conduct our business operations. Such information may be transferred to different countries that are within the EEA, that the European Commission has deemed as providing adequate protection of personal data, or that are parties to the EU-US Privacy Shield. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information.
  8. We may disclose your Personal Information or any information you submitted via the Services if disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Mindspace, our members, yourself, or the public.

10.  Use of Anonymous Information. We may use Anonymous Information or disclose it to third party service providers in order to improve our Services, offer Services and benefits, or improve our advertising effectiveness. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information that does not enable identification of an individual user, such as aggregated information about the use of our Services.

11.  Opting Out. You may choose not to receive future promotional, advertising or other Services-related emails, and text messages (SMS), etc. from us by selecting an unsubscribe link at the bottom of each message that we send. Please note that even if you opt out of receiving the foregoing messages, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Services. Opting out of Push notifications requires that you turn off push notifications on your device, or uninstall the application.

12.  Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Services but you may be unable to access certain applications, options, programs, offers, and services that involve our interaction with you.

13.  Access/Accuracy. To the extent that you do provide us with Personal Information, we need to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may use the tools that we make available on the Services or you may submit an access request by sending an email to privacy@mindspace.me. Your email should include adequate details of your request.  Notwithstanding the foregoing, we may retain certain Personal Information in connection with pending or potential legal disputes, as required by law enforcement or other government agencies, to process and maintain records of financial transactions, or as requested by you.

14.  Links to and Interaction with Third Party Products. The Services may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of these Third Party Services. Please be aware that the Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms, conditions, and privacy policy of each Third Party Service that you choose to use or interact with.

15.  Children’s Privacy. The Services are not structured to attract and are not intended for use by children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years. If we learn that we have collected Personal Information from a child under 18 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at privacy@mindspace.me.

16.  Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us at privacy@mindspace.me.

17.  Right to Obtain Information. You are entitled at all times to find out about your Personal Information we have stored, its origin and recipient as well as the purpose of the data processing. You will receive information about all your Personal Information that we have on record. To do so, please contact us at privacy@mindspace.me or at 45 Rothschild St., Tel-Aviv, 6578403, Israel, Subject: “Data Protection”.

Please also use one of these addresses in case you have any other questions relating to data protection of the Software/Services or require further information on a particular subject.

18.  Right of Revocation, Right to Delete your Personal Information. In accordance with the relevant statutory provisions, you have the right to correct, restrict or delete your Personal Information. You are entitled to revoke your authorisation for us to process and use your Personal Information at any time, effective from the time of revocation. To do so, please send us an e-mail indicating to info@mindspace.me or to 45 Rothschild St., Tel-Aviv, 6578403, Israel, Subject: “Data Protection”. Upon revocation of your permission or a request for deletion, we will delete your Personal Information completely, except where applicable obligations require us to retain your Personal Information. In these cases, the further processing or use of your Personal Information will be suspended.

Please note that depending on the nature and the scope of the Personal Information concerned, your revocation may impede the provision of the Mindspace Services.

19.  Merger, Sale or Bankruptcy. In the event that all or part of our business is acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events. If required by law, we will obtain your consent for such transfer.

20.  Commitment. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Services to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at privacy@mindspace.me or at 45 Rothschild St., Tel-Aviv, 6578403, Israel.

Last updated: 29th October 2017