Last Updated: June 30, 2023
By using or accessing our web or mobile application-based services (“Services”) in any manner, you acknowledge that
you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your
- Categories of Personal Data We Collect
- Categories of Sources of Personal Data
- Our Commercial or Business Purposes for Collecting Personal Data
Data” means any information that identifies or relates to a particular individual and also includes information referred
to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or
regulations. Open Space’s products are a business-to-business offering and, in the ordinary course of providing those
products, we may process personal at the direction of our enterprise customers (“Enterprise Customer”). This Privacy
Policy does not apply to our data use practices in connection with personal data collected from or on behalf of our
Enterprise Customer. The Enterprise Customer (e.g., your employer or another entity or person) that entered into a
Master Service Agreement, applicable terms, or another written agreement executed by us controls such data. If you have
any questions related to that Enterprise Customer’s settings or privacy practices, please contact such organization. If
we process your personal data on behalf of one of our Enterprise Customers and you wish to discontinue such processing,
or if you seek to correct, amend, or delete inaccurate personal data, please directly contact the organization on whose
behalf we are processing such personal data. We will follow the Enterprise Customer’s instructions with regard to the
personal data at issue. We will retain such personal data pursuant to our retention policy and will retain it as
not cover the practices of companies we don’t own or control, such as our Enterprise Customers, or people we don’t
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|Category of Personal Data||Examples of Personal Data We Collect||Categories of Third Parties With Whom We Share this Personal Data:|
|Profile or Contact Data||
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses
to surveys or questionnaires.
- When you send us an email or otherwise contact us.
When you use the Services and such information is collected automatically.
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
If you download our mobile application or use a location-enabled browser, we may receive information about
your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect
information transmitted from your computing device for the purpose of providing you the relevant Services,
such as information regarding when you are logged on and available to receive updates or alert notices.
We may use analytics providers to analyze how you interact and engage with the Services, or third
parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles and, in some cases
we may enrich the information you’ve provided with data we receive from third parties.
- We may use analytics providers to analyze how you interact and engage with the Services, or third
We receive information about you from some of our vendors who assist us with marketing or promotional
services related to how you interact with our websites, applications, products, Services, advertisements
- We receive information about you from some of our vendors who assist us with marketing or promotional
Business Partners, including our Enterprise Customers
If you provide your social network account credentials to us or otherwise sign in to the Services
through a third-party site or service, some content and/or information in those accounts may be
transmitted into your account with us.
We also may receive personal information about you from one of the organizations that we have a
contractual relationship with, such as our Enterprise Customers, to provide the Services.
- If you provide your social network account credentials to us or otherwise sign in to the Services
- When you provide such information directly to us.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in
applicable data privacy laws.
Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending
you information about Open Space or the Services.
Sending emails and other communications according to your preferences or that display content that we think will
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as
preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Open Space or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially
different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section.
Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your
Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our
behalf. They include:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
Our payment processing partner, Adyen S.A. (together with tehir affiliates, “Adyen”), collects your
voluntarily-provided payment card information necessary to process your payment.
- Our payment processing partner, Adyen S.A. (together with tehir affiliates, “Adyen”), collects your
Advertising Partners. These parties help us market our services and provide you with other offers
that may be of interest to you. They include:
- Ad networks.
- Marketing providers.
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They
- Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
Business Partners. These parties partner with us in offering various services. They include:
- Businesses that you have a relationship with, such as our Enterprise Customers.
- Companies that we partner with to offer joint promotional offers or opportunities or integrations.
Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set
forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for
Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger,
acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in
part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes
subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by
removing information that makes the data personally identifiable to a particular user. We may use such aggregated,
de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze,
build and improve the Services and promote our business, provided that we will not share such data in a manner that
could identify you.
Tracking Tools, Advertising and Opt-Out
(collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use
our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces
of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to
access our Services. We may also supplement the information we collect from you with information received from third
parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our
following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have
requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies
may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services,
maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to
personalize our content for you, greet you by name and remember your preferences (for example, your choice of
language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our
Services. They do this by collecting information about the number of visitors to the Services, what pages visitors
view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also
help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the
connection with its Google Analytics services. Google’s ability to use and share information collected by Google
www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at
Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and
identify your interests so that we can provide advertising that we believe is relevant to you. For more information
about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an
option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as
(depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a
variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have
to manually adjust some preferences every time you visit our website and some of the Services and functionalities may
not work. To explore what Cookie settings are available to you, look in the “preferences” or “options” section of
your browser’s menu. To find out more information about Cookies, including information about how to manage and delete
Cookies, please visit http://www.allaboutcookies.org/ or
https://ico.org.uk/for-the-public/online/cookies/ if you
are located in the European Union.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad
agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements
may be targeted to users who fit certain general profile categories or display certain preferences or behaviors
(“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or
derived from the usage patterns of particular users on the Services and/or services of third parties. Such information
may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the
Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web
beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated
auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted
advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own
Cookies on your browser, just as if you had requested a web page from their site.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical,
technical, organizational and administrative security measures based on the type of Personal Data and how we are
processing that data. You should also help protect your data by appropriately selecting and protecting your password
and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have
finished accessing your account. Although we work to protect the security of your account and other data that we hold in
our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide
you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our
legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule
or regulation. We may further retain information in an anonymous or aggregated form where that information would not
identify you personally.
Personal Data of Children
age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send
us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete
that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal
Data to us, please contact us at email@example.com.
State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent
disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such
a request, please contact us at firstname.lastname@example.org.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who
intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with
the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your
European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have
additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data,
as outlined below. For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR,
but “Personal Data” generally means information that can be used to individually identify a person, and “processing”
generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
Open Space will be the controller of your Personal Data processed in connection with the Services. If there are any
protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section
or whether any of the following applies to you, please contact us at firstname.lastname@example.org. Note as clarified above, that
we may also process Personal Data of our Enterprise Customers’ end users or employees in connection with our provision
of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your
Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your
rights with respect to such data.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal
Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing
include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the
legitimate interest of us or third parties:
- Profile or Contact Data
- Online Identifiers
- Device/IP Data
- Web Analytics
- Geolocation Data
- Sensory Data
- We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
- Providing, customizing and improving the Services.
- Marketing the Services.
- Corresponding with you.
- Meeting legal requirements and enforcing legal terms.
- Completing corporate transactions.
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time
we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at
the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal
obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary
for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about
these rights, or to submit a request, please email us at email@example.com. Please note that in some circumstances,
we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it
jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to
notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may
include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a
copy of such Personal Data. You can also access some of your Personal Data by logging on to your account or by
contacting us at firstname.lastname@example.org.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or
incomplete, you can request that we correct or supplement such data. You can also correct some of this information
directly by logging on to your account or by contacting us at
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated
at the time of collection of such data), you have the right to withdraw your consent at any time. Please note,
however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for
the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to
utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can
also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of
your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Open Space’s practices with
respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of
Supervisory Authorities is available here:
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Open Space and its service providers, and if
you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you
acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is
being provided to Open Space in the U.S. and will be hosted on U.S. servers, and you authorize Open Space to transfer,
store and process your information to and in the U.S., and possibly other countries.
will alert you to any such changes by placing a notice on the Open Space website, by sending you an email and/or by some
other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us
with your email address), those legal notices will still govern your use of the Services, and you are still responsible
the time such information is collected.
or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
- Perry Li, Director, Legal
- 333 Kearny St. 4th Fl. San Francisco CA 94108