Startup Marketing? How Honesty Can Boost Your Success

Soho Workspaces Inc. and our affiliates (collectively “The Farm,” “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 The Farm 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”). 

The Farm has many affiliated entities that act as data controllers around the world who will act as the data controller for your Personal Information, and your Personal Information may therefore be shared with entities outside of the jurisdiction in which it was collected. For more information on the data controller for your jurisdiction please review the list of our global entities for the name of the The Farm entity responsible for your Personal Information and the appropriate contact information for that entity.

We want to help you build a life, and not just a living, 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 The Farm. You can read more about how Personal Information is used by clicking below on the name of The Farm 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.

COVID-19.   We may collect, use, disclose, and otherwise process your Personal Information in connection with our response to COVID-19.

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.
• that your company, broker, host, parent, or guardian provides to us;
• 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; 
• from third parties such as our landlords, building managers, licensees and property brokers); and
• that we obtain from other sources, including data brokers or information providers (such as Dun & Bradstreet). 

INFORMATION COLLECTED FROM YOU

The Farm 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, mailing address, phone number, email address, and other information that enables us to contact you;
• Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth;
• Professional and Employment-Related Information, including your company name, title, role, team, and other information about your profession;
• Payment Information, including your credit or debit card details, bank account information, and payment or other information required when you make a purchase;
• Email Calendar Information, when we integrate with your corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book;
• Office Preferences, including your requested or preferred temperature, fan speed, desk and chair height, desk location, phone booth, beverage, snack, and other preferences related to the Services;
• Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit a The Farm 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 about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, as further set forth in our Cookie Policy, and your offline activity, including information about events you attend at The Farm locations; and
  • Information gathered by sensors about how you use our Services, including through Spatial and People Analytics Sensors (“SPA Sensors”) in offices, kitchens, conference rooms, and other spaces of some facilities that you may work in or visit, to promote more efficient and comfortable uses of the Services. Examples of SPA Sensors include desk occupancy sensors, environmental sensors, WiFi network hubs, and optical camera-powered sensors.
• Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the time and purpose of your visit, photos of you, and data or files that you input, upload, or store with the Services, such as search queries that you submit, and documents that you upload to the Services. We will also process Personal Information included in content and information that you add to your member network or other community profile. 

INFORMATION COLLECTED ABOUT YOU

• Social Media. The Farm collects Personal Information to enable you to use online social media resources, including the use of our Member Network (MENA). If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.
• Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest to one of our spaces. We also may receive your Personal Information from publicly and commercially available sources, as permitted by law and other third parties with whom we have an arrangement . We combine this information with Personal Information or other information that we receive from or about you, where necessary to provide the Services you requested. If we obtain Personal Information about you from a third party, we will confirm that the Personal Information is from a legitimate source.
• 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, The Farm 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 The Farm to enable you to access your user accounts and to enable The Farm to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

ANONYMOUS, AGGREGATED, AND OTHER INFORMATION

We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.

In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.

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 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; 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.

LEGAL BASES FOR PROCESSING PERSONAL INFORMATION IF RESIDENT IN THE UK AND EU

The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others with a secure environment, analyzing, improving, and better tailoring our products and Services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.

We also generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third-party websites, and in providing promotions or sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt-out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.

4. SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to The Farm, our community, our service providers and advertisers, other end users, in order to provide our Services and to improve ways of working in our community and where required by applicable law. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent. 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: 

• Among The Farm. We may share your Personal Information among The Farm businesses or entities depending on where you are located and the Services that you use. The Farm 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:
  • Our Services may make member networks, chat rooms, forums, and/or other groups available to users. Remember that anyone can read, collect, or use your postings on a network or forum or in a chat room or group and we cannot be responsible for any unauthorized third party’s use of information that you publicly disclose online.
  • We foster our community by creating profiles for members or permitting members to create their own profiles on member networks or forums. Typically, such a profile contains your name, the name of your company, and other information you provide or add to your profile (content, comments, photos, etc.). Depending on the Services you use, this profile might be created automatically and be accessible to other members of the network or forum. Member Network profile information is accessible to all members. You can also share your profile with a broader audience (e.g., via social media).
  • When we receive information about you in connection with your relationship with our members or clients—for example, if you are a member’s employee or if you are visiting one of our clients—we may share your information with the member or client with which you have such a relationship, for example, by alerting the member or client that you have arrived to visit. Please note that we are not responsible for the privacy practices of our members or clients, or their third-party service providers, including those they integrate with our Services.
  • 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 mentoring program, we may share information about you with potential mentors.
• Primary Members. Information on the utilization of our services by individual members may be shared with the primary member or the organization who purchased the memberships.  Examples of individual members are employees of a member company or students of a member university.
• Suppliers and Vendors. We rely on various third-parties to perform a variety of services on our behalf and to help us grow and improve our business. We take steps to ensure that where we share your Personal Information with these third parties that they act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.

Landlords and Building Management.  In some cases we may share your Personal Information with our landlords and/or building management at The Farm properties so that they can effectively manage and operate the building.

• • Licensees. We share your Personal Information with our licensees, for the purposes described in this Global Privacy Policy, such as providing and personalizing the products and services, fulfilling your requests, providing their own marketing and complying with their legal and contractual obligations. For example, this sharing of Personal Information enables you to utilize The Farm’s products and services in certain countries. 
  • 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.
  • Third-Party Advertising Partners.  We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.

• 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 or your company 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 the The Farm companies, business partners, members, or employees; and
  • where otherwise required by applicable law.

We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.

• Other Parties in Connection with a Corporate Transaction.  We disclose or share your information in the event that we purchase, sell, finance, transfer, or acquire all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
• Other Third-Party Partners, in Connection With your Membership Agreement. When the terms of your Membership Agreement allow, and where permitted by applicable law, we may disclose or share your contact information with select third-party partners who may contact you to offer additional services related to your Membership. You may opt out of further communications with such third-party partners by contacting The Farm and are under no obligation to meet with third-party partners or purchase additional services.
• Other Third-Party Partners, With Your Consent.  We may request your consent to share Personal Information about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicize your name, likeness, and other personal characteristics and private information for advertising, promotion, and other commercial and business purposes.

4.1 THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES

We partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example:

• Third parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.
• Advertising providers help us, and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.
• Other content providers offer products and services on our Services and operate contests, sweepstakes, or surveys on our Services.

We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). For more information on these types of tracking tools, please see our Cookie Policy. We also share such information that we have collected with third-party advertising partners. These advertising partners use this information (and similar information collected from other websites) to deliver future targeted advertisements to you when you visit non-The Farm related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

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.

4.2 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 The Farm, 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 The Farm 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 [email protected] or at one of the physical addresses set out in the list of global entities top of this Policy.

We will process all such requests in accordance with local laws. To protect your privacy, The Farm 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 The Farm’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, The Farm 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, The Farm 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 The Farm 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.
• Text Messages. We may send you SMS text messages related to our Services or transactions. You can opt-out of these messages at any time by replying STOP.

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 The Farm at [email protected] 

If you are based in India you may submit any complaints to our Grievance Officer at: [email protected]

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. INTERNATIONAL TRANSFERS

The Farm is headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard contractual clauses, to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out at the top of this Policy and below in Section 12.5

9. 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 The Farm is important to us. The Farm 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

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

The Farm’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 The Farm, including landlords, building managers, licensees and brokers.

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 The Farm.

11.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding this Policy, please contact us at [email protected]

If you would like to contact us in writing, please see our list of global entities at the top of this Policy for contact information of the data controller for your jurisdiction. 

If you are based in a jurisdiction where the law requires that The Farm has a Data Protection Officer, please submit your query to [email protected]

The Farm 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.

12. CALIFORNIA AND CCPA-SPECIFIC INFORMATION

California Privacy Rights

California residents who are registered members or users of the Services and are under the age of 18 may be entitled under California law to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at [email protected] In your request, please provide a description of the material that you want removed and information sufficient to permit us to locate the material, including your name, email address, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request.” Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.

California Consumer Privacy Act (CCPA)

We have explained our privacy practices in the other sections of this Privacy Policy. In this section, we supplement those descriptions for California residents by providing a list of categories of personal information as set forth in the CCPA that have been collected or disclosed for a business or commercial purpose during the preceding 12 months, as well as certain other information. Please see the other sections of the Privacy Policy for additional information and context.

Category of Personal Information Explanation. 

• Contact Information and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you. We may use this information to respond to your questions, to enable you to participate in our programs (including promotions or sweepstakes), to provide you with online and offline events, to provide our Services, and for other business purposes.
• Professional and employment-related information, including your company name, title, role, team, and other information about your profession. We may use this information to provide you with the products and Services you request, and for other business purposes.
• Commercial information, such as a record of your purchases, and Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit a The Farm location. We may use your information to provide you with the Services you have purchased, to identity other products and offers that may be relevant to you, and for other business purposes.
• Internet and electronic network activity information, such as information about your interactions with our Services. We may use this information to improve our Services, to better understand the visitors who come to our Services and what content is of interest to them, and for other business purposes.
• Precise geographic location information, using technologies such as GPS or WiFi. We may use this information to improve the quality, security, and relevance of our Services to our visitors, and for other business purposes.
• Other electronic or visual information, including information that you share using the Services (such as videos or photos) or footage captured by CCTV. We may use this information for our business purposes. For example, we use videos or photos that you share to provide the services you ask for on our Services, as part of sweepstakes or other competitions; and we use footage captured by CCTV to provide a Secure Environment.     

As discussed in the other sections of our Privacy Policy, we collect this type of information from you, through our interactions with you and others, and from third parties, and we disclose all of these categories of Personal Information within the The Farm companies and our community, to service providers and third-party advertising partners, and as needed to comply with legal process. Your Personal Information may also be shared with third parties with whom you interact and third parties that you direct us to share your information with through our Services, and you may learn about your choices for third-party advertising cookies and similar technologies in our Cookie Policy. 

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, The Farm does not “sell” personal information, nor do we have actual knowledge of any “sale” of Personal Information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Exercising Your Rights 

You may exercise your rights as a California resident by calling +1 (906) 629-1755, or by contacting The Farm at [email protected] We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. 

When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth above.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, phone number, and/or mailing address. 

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 [email protected]