Privacy Policy

This document explains how Ellyot handles information about you which is personally identifiable (“Your Information”) when you use Ellyot App or Ellyot Web Page

Last Updated: February 14, 2018

1 Background

1.1 Key Definitions

For Key Definitions have a look at “Ellyot Main Terms”.

Please note that in this Privacy Policy “You” means the “User”.

1.2 Ellyot (hereinafter referred to as “Ellyot”, “we”, “us” or “our”) provides an online Web Page and/or App that connects Venues that have Desks to list with people (“Users”) seeking to book such Desks (collectively, the “Services“). These Services are accessible at www.ellyot.com and at any other websites through which Ellyot makes the Services available (collectively, the “Web Page”) and as applications for mobile, tablet and other smart devices and application program interfaces (collectively, the “App”).

This Privacy Policy is intended to inform you about how we treat “Personal Information” that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Web Page and/or App or Services to you, and you should stop accessing the Web Page and/or the App and deactivate your Ellyot Account.

2. What types of information does Ellyot gather about its users?

2.1 Information that you give us

We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Web Page and/or App and Services.

Examples include when you:

a) fill in any form on the Web Page and/or the App, such as when you register or update the details of your user account, or when you supply ID and other verification information;

b) access or use the Web Page and/or the App, such as to search for Desks, make bookings, pay for Desks, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;

c) link your account on a Third-Party site (e.g. Facebook) to your Ellyot Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

d) communicate with Ellyot; and

e) share information with another Member.

2.2 Information we get from your use of our Web Page and/or App

We also receive, store and process information, possibly including Personal Information, when you access or use our Web Page and/or App and Services, including but not limited to:

A. Mobile Data

When you use certain features of the Web Page and/or the App, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Web Page and/or the App or specific features of the Web Page and/or App). If you access the Web Page and/or App through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

B. Contact Information

You may use your contact information, such as your email address or phone number or to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address or phone number, you agree to receive emails to that email address or text messages to that phone number as the case may be. We may use your contact information to send you information about our Web Page and/or App and Services, to market to you, and to help prevent spam, fraud, or abuse.

C. Log Data

We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Web Page and/or the App, regardless of whether you are registered with Ellyot or logged in to your Ellyot Account, such as your IP Address, the date and time you access or use the Web Page and/or App, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

D. Cookies and other Tracking Technologies

Ellyot may use cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Web Page and/or the App, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Ellyot services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

We may, either directly or through Third Parties we engage to provide services to us, track your behavior on our own Web Page and/or App for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Web Page and/or App and pay for your activities on the Web Page and/or the App. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Web Page and/or App to market and advertise our services to you on the Web Page and/or App and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Web Page and/or App and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance.

You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Web Page and/or App – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Web Page and/or App, Application and Services, as cookies are necessary to track and enhance your use and access.

Third Parties may not collect information about Users’ online activities on the Web Page and/or App except as described in this policy and in this cookie policy (please see below).

E. Third-Party social plugins

Our Web Page and/or App may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Web Page and/or App. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Web Page and/or App to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.

3. How Ellyot uses and processes the information that you provide or make available

We use, store and process information about you for the following general purposes:

a) to enable you to access and use the Web Page and/or the App;

b) to enable you to communicate with other Members;

c) to operate, protect, improve and optimize the Web Page and/or the App, Ellyot’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

d) to help create and maintain a trusted and safer environment on the Web Page and/or the App and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

e) to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

f) to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Ellyot, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications;

g) to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Ellyot or our Third Party business partners; and

h) to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

4. How Ellyot Uses and Processes User Communications

We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyse your communications with other users exchanged via the Web Page and/or App for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes.

For example, as part of our fraud prevention efforts, the Web Page and/or App may scan and analyse messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Users to send them money outside of the Web Page and/or App, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings.

We will not review, scan, or analyse your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Web Page and/or App, you consent that Ellyot, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyse, and store your communications, whether done manually or through automated means.

5. When Ellyot discloses or shares your personal information, and to whom

IMPORTANT: When you use the Web Page and/or App, your data may be sent to other countries in accordance with this Privacy Policy.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Web Page and/or App, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

5.1 Your Personal Information may be transferred, stored, used, processed and disclosed as follows:

a) Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Web Page and/or App to other users for marketing purposes or if you post content in a community forum or other features on the Web Page and/or App that are visible to the general public.

b) When you book a Desk, we will disclose some of your Personal Information to the Venue(s). However, your billing and payout information will never be shared with another User.

c) If You activate the “User Work Location Feature”, you acknowledge, consent and agree that Ellyot can share the location of your current Bookings and other Personal Information of yours with other Users.

d) If a User books a Desk for a business mission, and the User is engaged or employed by a company or other organization (either or both a “User Affiliated Organization”), we may disclose the name of the Venue and the address and other Desk information to the User Affiliated Organization.

e) If you as a User are associated with a User Affiliated Organization, we may share with it information related to your bookings. Further, if you have linked your Ellyot Account to a User Affiliated Organization and indicate that a booking is for business purposes, we may disclose your booking information (which may include your Personal Information) to such organization. Typically, this information will include your name, dates of the booking, number of Users, cost of the booking, and the address of the booking. In addition, if your User Affiliated Organization has requested that we provide it with information in the event of a dispute, emergency or similar situation involving your bookings, we may notify such organization of the situation and disclose to it any information, including your Personal Information, that we believe in good faith is necessary to safely and quickly resolve or address the situation.

f) When You stay at a Venue’s Desk, we may ask you to review the Venue or the Desk. If you choose to provide a review, your review may be public on the Web Page and/or App. Likewise, another Member’s review of you as a User or of Venue(s) may be public on the Web Page and/or App.

g) You may link your account on a Third-Party social networking site to your Ellyot Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:

• some of the information you provide to us from the linking of your accounts may be published on your Ellyot Account profile;
• your activities on the Web Page and/or App may be displayed to your Friends on the Web Page and/or App and on a Third-Party site;
• a link to your public profile on that Third-Party social networking site may be included in your Ellyot public profile;
• other Ellyot users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
• other Ellyot users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);
• the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
• the publication and display of information that you provide to Ellyot through this linkage is subject to your settings and authorizations on the Web Page and/or App and the Third-Party site.

h) Ellyot may provide your Personal Information to its Affiliates and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. Ellyot may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom Ellyot has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications.

i) We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request. We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

j) You acknowledge, consent and agree that Ellyot may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Ellyot; (b) to comply with legal process (for example, subpoenas and warrants), including legal process associated with national security and law enforcement; (c) to enforce and administer our agreements with users, such as the Ellyot Main Terms, the Ellyot Terms of Service, the Payments Terms, the Non-Discrimination Policy and this Privacy Policy; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Ellyot, its users or members of the public.

k) We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

• providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
• we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Ellyot’s property, its Members, the Web Page and/or App, Application, or Services (collectively, “Risk Scenarios”).

In instances where Ellyot complies with legal requests for User data without notice to the User for the reasons described above, Ellyot will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

l) We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

6. Business transfers by Ellyot

If Ellyot undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

7. How to access, change or delete your information, or cancel your Ellyot account

You may review, update, correct or delete the Personal Information in your Ellyot Account. If you would like to correct your information or cancel your Ellyot Account entirely, you can do so by logging in to your Ellyot Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Web Page and/or App in association with your first name, even after your Ellyot Account is cancelled.

8. Securing your personal information

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

9. Your privacy when you access third-party websites and resources

The Web Page and/or App will contain links to other websites not owned or controlled by Ellyot. Ellyot does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Web Page and/or App implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use and Google’s privacy policy, as may be amended by Google from time to time

10. Changes to this privacy policy

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Web Page and/or App or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Web Page and/or App and Services to you, and your only option will be to stop accessing the Web Page and/or App and Services and deactivate your Ellyot Account.

11. COOKIE POLICY

Ellyot may use “cookies” in conjunction with the Web Page and/or App to obtain information. A cookie is a small data file that is transferred to your device for record-keeping purposes. For example, a cookie could allow the Web Page and/or App to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Web Page and/or App may not work as intended or may not work at all without cookies.

11.1 Ellyot cookies and Third Party cookies

Ellyot may place our cookies on your device via the Web Page and/or App. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Web Page and/or App, namely “persistent cookies” and “session cookies”.

Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Web Page and/or App.

11.2 Other technologies

The Web Page and/or App may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

11.3 Uses for Ellyot cookies

Ellyot uses cookies and similar tracking technologies for a number of purposes, such as the following:

• to enable, facilitate and streamline the functioning of the Web Page and/or App across different webpages, devices and browser sessions.
• to simplify your access to and use of the Web Page and/or App and make it more seamless.
• to monitor and analyse the performance, operation and effectiveness of the Web Page and/or App, so that we can improve and optimize it.
• to show you content (which may include advertisements) that is more relevant to you.
• for fraud detection and prevention.

11.4 Uses for Third-Party cookies

Our partners’ cookies are intended to obtain information to help them provide services to Ellyot. For example, Third Parties we engage to provide services to us may track your behavior on our Web Page and/or App to market and advertise Ellyot listings or services to you on the Web Page and/or App and Third-party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites that use cookies and other tracking technologies to deliver targeted advertisements on our Web Page and/or App and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Web Page and/or App – it just will not be tailored to your interests.

11.5 Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Web Page and/or App. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies.

11.6 Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Web Page and/or App or by sending you an email.

It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Web Page and/or App to you, and your only option is to stop accessing the Web Page and/or App and Services and deactivate your Ellyot Account.