Privacy Policy

I. INFORMATION WE COLLECT FROM YOU

 Personal Data

We collect the following categories of information (which may include potentially personally identifiable data (“Personal Data”) from individuals who access our Services:

• Information that is voluntarily provided when you create an account to use our Platform, while using the Services, when you contact us with inquiries or for support, or when you fill out a form or respond to a survey. This may include your name, email address, city, license plate number, company affiliation, property location, and phone number. When you invite guests to your building using our Platform, we collect the information you provide such as the guest’s name, email address, and phone number. Depending upon the Services provided, Cohesion also obtains location information through your IP address, when you grant background location permission when using the Services, and through beacons located at a property. Cohesion also obtains and stores any pictures, photos, images, and other information you submit in connection with a service request made through our Services. Cohesion may store your purchase information, but we do not keep your credit card information.
• When you visit our website, we will use cookies and similar technologies like pixels and web beacons to collect information. We automatically collect information about your device including but not limited to your IP address, browser type, internet service provider, hardware, operating system version, mobile network, and unique device identifiers. Additionally, as you browse our website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the site, and information about how you interact with the site.  
• Additional information automatically collected when using Cohesion’s software Platform includes individual user data such as a user’s name, company, email domain, location, email address, browsing environment, referral URL, device information, and user type (i.e., tenant or building manager). We also collect information to understand your interaction with the Platform including number of web sessions, date and time of visits,  iOS and Android sessions, app version, device ID and OS version, user interaction patterns, IP address and platform.
• So that you can use our Platform, such as for building access, we acquire your device level ID. To avoid interruptions to our Services, we receive notification when your device crashes.

A company in a building that offers our Services may also provide us certain of the above information for its employees, so we can initiate bulk account registrations and invite the building’s tenants to access the Services. Those registrations may also be automated so that new accounts are created or removed as employees come and go from the company.

Aggregated Information

When you interact with Cohesion’s Services, we collect some information that cannot be specifically identified to you, to track aggregate statistics like the total number of users of our Services, the number of visitors to particular pages, etc. We may store that information at Cohesion or include it in databases owned by our affiliates, agents, or service providers. No Personal Data is used in this process. To the extent the use of our Services generates location data or other Personal Data (for example, if a user engages the Services to access a turnstile at their office), we may also strip it of Personal Data and use it as anonymous, aggregate information.

 II. HOW WE USE THIS INFORMATION  

Personal Data  

We use Personal Data for the purpose it was solicited—for example:

• To verify that an individual is an authorized user eligible for access to our Services;
• To provide users and their authorized guests with the Services;
• To make sure functionality that is dependent on Personal Data (like access control) works for the relevant individual;
• To understand how visitors use our website to make it better;
• For marketing purposes;
• To diagnose and fix technology problems;
• To track user activity on our software Platform, such as click patterns and time on our site;

• To improve the Services or develop new products and services;
• To send notifications to users
• To respond to a request for support; and
• To manage and comply with our contractual, legal, and/or regulatory obligations, including to enforce the terms of our site and Services, to address emergency situations, and to comply with our obligations under applicable laws and regulations.
  

Aggregated Information  

We use aggregated, non-identifiable information to:  

• Understand and improve building workflows;
• Conduct research and develop statistics on the usage of our Services;
• Customize and develop new and existing product offerings;
• For marketing purposes; and
• Improve the content and functionality of our Services.
  

III. HOW WE DISCLOSE THIS INFORMATION  

We take your privacy very seriously. The Personal Data we collect is limited to what we need to provide our Services. We do not sell your information to third parties.  

We generally do not disclose Personal Data in the normal course of our business. However, there may be certain circumstances in which we may share your Personal Data without further notice to you:  

• In limited circumstances, we may disclose information to third parties who already have it (for example, if you are having trouble with a feature of our Services, we may in the course of troubleshooting discuss your name or company e-mail address with the employer that has verified you as a building tenant).  
• From time to time, we may use the services of our affiliates and third-party service providers or licensors to provide our Services, and we may disclose limited Personal Data to them if needed to perform their specific function. In such circumstances, we require the third parties to commit to protect the confidentiality of such information, but such third parties may have their own privacy policies and procedures and are otherwise responsible for their own compliance with data protection laws. We also use Google Analytics to help us understand how visitors use our website. For more information about Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners’ Sites Or Apps.”  
• In the event of a corporate sale, merger, reorganization, or similar event, Personal Data may be part of the transferred assets, in which event your information (including Personal Data) may be shared, sold, or transferred, and may be subsequently used by a third party.
• We may disclose aggregated, non-personally identifiable information with business partners, prospective customers, and other third parties.  
• If required to comply with legal obligations, to prosecute or defend claims by or against Cohesion, to protect the personal safety of users of our Services or the public, and to protect our rights.

For legal proceedings, we may disclose Personal Data: (a) to a governmental authority as part of an investigation to determine Cohesion’s compliance with any applicable law, rule or regulation (including privacy laws, rules and regulations); (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding; (c) as otherwise required under any applicable law, rule, or regulation; or (d) in good faith, to protect or defend the rights or property of Cohesion and our customers or users.  

Your Personal Data will be kept for only as long as reasonably necessary to fulfill the purposes for which it was collected, taking into account our need to comply with contractual obligations, resolve customer service issues, comply with legal requirements, and provide new or improved services, unless a longer retention period is permitted or required by law. We may retain Personal Data in anonymized and/or aggregated form for backups, archiving, prevention of fraud and abuse, analytics, to improve our service, or where we otherwise reasonably believe that we have a legitimate reason to do so.  

We may use third party licensors to deliver the Services to you such as ActionFigure for transportation information. This Privacy Policy does not apply to these third-party sites and providers. Rather, those sites are subject to their own rules and policies. This includes third party provider ActionFigure’s privacy policy available at https://www.iubenda.com/Privacy-Policy/446002/Legal.

IV. HOW WE PROTECT THIS INFORMATION  

We protect Personal Data through security safeguards that are consistent with the standards we use to protect our own confidential and proprietary information. These safeguards include the use of confidential passwords to access the Services and imposing confidentiality requirements on our employees. However, please bear in mind that no information is ever 100% secure, and we cannot and do not guarantee the security of your information.

 V. YOUR OPTIONS AND CHOICES ABOUT YOUR INFORMATION  

If you are a user of our Services and have an account with us, you may log in to your Cohesion account to review, update, or delete Personal Data if you have been granted the authority to do so. However, you may need to keep your account active with minimal Personal Data if your place of work utilizes our Services as the only means of access to your space.

In the event you wish to have your account deleted and no longer access services through the application, please email Support@CohesionIB.com from the same email address you currently use to access the application with the subject “User Account Deletion” and include the following statement in the body of the email “Please delete the user account with the email address [enter email address] for user [First and Last name]”.  

You may opt out from receiving future promotional or informational emails from us by following the instructions for unsubscribing in the emails we send to you. However, you cannot opt out of transactional emails related to your account registration or other transactions with us.

Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. Please be aware that if you change the preferences on your device to prevent or limit your device’s acceptance of cookies, this may prevent you from taking advantage of some of the features on our site or Services. For more information about cookies, and how to disable cookies, visit http://allaboutcookies.org.  

While we take all reasonable steps to protect the privacy of our site users and visitors, we cannot promise that our online applications programming will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications programming is refined, we will take reasonable steps to honor such requests in the future. Please return to this Privacy Policy for further updates on this topic.

VI. LOCATION OF THE SITE AND SERVICES

Our site and Services are operated and hosted on servers in the United States. However, we and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries.  

Visitors from jurisdictions outside the United States visit our site and use our Services at their own choice and risk.

If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States from which you may access our site and Services may not be as stringent as that under privacy standards or the privacy laws of other countries, possibly including your home jurisdiction.

VII.  PRIVACY NOTICE FOR CALIFORNIA USERS

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” as defined by the California Consumer Privacy Act (“CCPA”).  Cohesion is currently not subject to the CCPA but please see above for the information we collect and how that information is used and disclosed. Please note that we do not share personal information with third parties for their own marketing purposes. If you are a California resident and have questions about our practices, please contact us as provided below.  

VIII.  THIRD-PARTY LINKS

Occasionally, at our discretion, we may link to third-party products or services on or through our site or Services. These third parties have separate and independent privacy policies. We therefore have no responsibility or liability for the content or activities of these linked sites. We urge you to read the privacy policies of other websites before submitting any information to those websites.

IX. INFORMATION ABOUT CHILDREN

Our site and Services are not intended for use by children under 13 years of age. If you are under 13, do not use or provide any information on our site or Services, or on or through any of their features, without the supervision and express consent of your parent and/or legal guardian. If we learn we have collected or received Personal Data from a child under 13 without verification of parental or legal guardian consent, we will delete that data. If you believe any information about your child under 13 has been submitted to or collected by us without your consent, please contact us at legal@cohesionib.com.

X. EXCLUSIONS

If you provide us with any suggestions or product ideas, you agree that such information is non-confidential and that Cohesion is free to use, reproduce, disclose, and distribute it to others without limitation or attribution. In addition, please note that this Privacy Policy only applies to information collected by Cohesion through our Services. This Policy does not apply to any third-party sites which our website may link to, and our inclusion of such links does not imply that Cohesion endorses or has reviewed the sites or their privacy policies, which you are encouraged to review directly.  

 XI. QUESTIONS

Our goal is to ensure that our privacy practices are comprehensible and easy to understand. If you have any questions or comments, please email us at legal@cohesionib.com.