Privacy Policy

Effective: 1st of March 2024
Last Revision: 1st of March 2024

Table of Content

Our relationship with you
Legal Bases for the Processing of Personal Information
Personal Information We Collect
How do we use the personal information we collect?
Who do we share personal information with?
Sub-processor
Your rights
Retention of Information
Security and Storage
International Data Transfers
Analytics & Advertising
Third-party Links and Websites
Children's Online Privacy Protection Act Compliance
Change of Ownership
Changes to our Privacy Policy
Complaints
Contact Us

PONT Technologies Ltd. (Company Registration Number 15045580), with a registered office at 23a Sandy Lane, Church Crookham, Fleet, England, GU52 8LA (referred to as "PONT," "we," "us," or "our"), provides an online service and app for booking workplaces and events. This privacy policy explains how we collect, use, share, and protect your personal information either as PONT or under our partner brands (“White-Label”), e.g. Brave.

We appreciate the trust you place in us when you use the PONT platform and our services. As a result, we process the personal information we receive from you responsibly and in accordance with applicable laws and regulations.

This Privacy Policy describes how we process the personal information collected when you and your Users access this website (“Website”) or our mobile applications (“Mobile Apps”), being the applications in any of the white label versions provided to our customers and partners. Together, the Website and Mobile Apps are the PONT Platform (“PONT Platform” or the “Services”). When you leave the PONT Platform, this Privacy Policy no longer applies. Any subsequent website, application, or service you access will have its privacy notice and other applicable terms.

This Policy tells you about your rights and choices concerning your personal information, including how you can contact us if you have any questions or concerns. In this Privacy Policy, “Personal Information“ means any information relating to an identified or identifiable individual.

Please read this Privacy Policy carefully. If you do not agree with this Privacy Policy or any part thereof, you should not access or use any part of the Services. If you change your mind in the future, you must stop using the Services. You may exercise your rights in relation to your Personal Information as set out in this Privacy Policy.

PLEASE NOTE: If you provide Personal Information to PONT on behalf of your Users you must give notice to your Users and this Privacy Notice must be incorporated into the privacy notice you provide to your Users.

PLEASE NOTE: If you are a third-party processing personal information generated by the PONT Platform, you must notify your Users regarding how you are processing the personal information, and this Privacy Notice must be incorporated into your privacy notice. This includes space partners providing third-party spaces to be reserved via the PONT Platform.

1. Our Relationship with You

In situations where you are subject to the Terms & Conditions for the use of the PONT Platform, PONT is the processor/service provider (a provider that processes personal information on behalf of or at the direction of a controller or other similar designation under the law), and you (usually a company or organisation) are the controller/business (the entity that decides how and why information is processed) of the information provided to PONT. In all other cases, PONT is the controller of the personal information.

The PONT Platform can be used by companies or by individual Users. If you’re utilising the Services through your company, educational institution, or with your company email address, your company or academic institution’s own Administrator is responsible for the accounts associated with that company or institution and can restrict, suspend, or terminate your access to or ability to use the services, access information about you, access or retain information stored with us (including your workspace content and log data about your use of the Services), and restrict your ability to edit, restrict, modify, or delete information associated with your use of our products and services.

2. Legal Bases for the Processing of Personal Information

If you are located in the EEA, UK or Switzerland, our legal basis for processing your Personal Information is described in this section:

Consent. This is the case where you have consented to the use of your personal information.
Contract. We need your Personal Information to provide you with our Services to perform our obligations associated with our contract with you, such as to create and secure your account or to respond to your inquiries.
Legitimate Interest. We have a legitimate business interest in processing your Personal Information to provide the Services to our Customers. We only rely on legitimate interest as a legal basis when our legitimate interests do not override your fundamental rights and freedoms associated with privacy and data protection. We ensure we comply with your requests to exercise your rights.
Legal Obligation. We may have a legal obligation to process your Personal Information, for example, to comply with tax and accounting obligations, and we may process your Personal Information when necessary to establish, exercise, or defend legal claims. We may also process your Personal Information when required to protect your or another individual’s vital interests.

3. Personal Information We Collect

When you visit the PONT Platform, we collect (1) technical information that is used to deliver the contents and services and for other purposes as described below and (2) information that you or your Members voluntarily submit.

Personal Information You Provide to Us

We collect a variety of information that you provide to us. The specific types of information we collect will depend upon your engagement with the PONT Platform.

Account Information. Suppose you create an account to use the Services as the account administrator (“Administrator”) or accept the invitation to register as a User (“User”) under an Administrator’s In that case, we collect Personal Information to allow you to use our Services via this account. When you sign up, you provide us with your name, password, email address, physical address, mobile phone number (optional), company name (optional), job title (optional), photograph (optional), interests (optional), opportunities you are open to (options), desire to be a part of the community, expectations from the community (optional), geolocation, booking history, and other account information necessary to create and maintain your account.
Community-related information.

Information you provide in your profile is, by default, shared with all Communities hosted by the PONT Platform and across all the whitelabel app versions managed by PONT. You can manage sharing preferences in your settings and limit or turn off sharing.

Contact Information and Other Information You Choose to Provide to Us. You can provide various information during your interactions with us, such as through emails or other communications. When you contact us via a website contact form, email, or other means, you provide us with Personal Information, such as your name and contact details, and the content of your communications.
Support Information. When you request technical support services, we will process your Personal Information, such as your name and the contact details you use to contact us, as well as information regarding the reasons for your support request, the support that was provided, and any additional information you may provide in that context.
Financial Information. If you purchase our Services, you will need to provide payment information that will be managed in compliance with the Payment Services Directive (PSD). We will use that information solely for the purpose of fulfilling your purchase request and won’t store any credit card information.
Other Information. You may choose to directly provide us with information associated with your use of the Services. For example, if you decide to use the Services offered, we will collect and store the content and information you create or upload to the account on the PONT Platform (“User Content”).

Information Collected Automatically

We may automatically collect certain information on the PONT Platform based on your behaviour. We use this information to conduct internal research on system usage, demographics, interests, and behaviour to better understand who is using the PONT Platform for marketing purposes and to improve our services. Whenever possible, the collected data is de-identified, aggregated and/or anonymised.

Single Sign-On Through Internet Service Providers. We may collect Personal Information from internet service providers when you decide to use their single sign-on servers to connect to our Services. The

privacy notices of the corresponding platform govern your interactions with these tools.

Device and Usage Information. When you access and use the PONT Platform, we receive and store information about your interactions, such as date/time stamps, usage information and statistics, your internet protocol (IP) address, hardware and software information (including operating system version and type), browser type, device identifiers, device event information, crash data, cookie data, and the pages you have viewed or engaged with before or after accessing the PONT Platform including content accessed, time viewed, links clicked, referring/exit pages, and clickstream data. This information could be used to identify you or your device and may provide us with your location.
Cookies and Similar Technologies. We collect Personal Information via cookies, pixel tags, or similar technologies on the PONT Platform (collectively referred to as “Cookies“). For more information on our use of Cookies, please read our Cookie Notice .
Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).
Information from Other Sources. We may collect information about you from third parties, such as marketing partners and researchers. We may combine this information with information we collect from you and use it as described in this Privacy Notice.

4. How Do We Use the Personal Information We Collect?

We use the Personal Information we receive or collect for the following purposes:

To create your account for your use of the Services.
To provide our Services, including operating, maintaining and supporting our Services by making available our online database with business contact details to Administrators and Users.
For personalisation to customise our Services to meet your specific needs.
For product improvement as described in our Terms&Conditions , to improve the Services and to develop new products, services, and features.
To communicate with you by phone, text, email, or chat. This may include contacting you for administrative purposes such as security or support and maintenance advisories, to provide services and information that you request, to respond to comments and questions, to contact you regarding issues concerning your use of our Services, including changes to this Privacy Notice, and to provide customer support otherwise.
Subject to any consent requirements, send marketing materials and alerts about the latest developments and features or other promotional materials and develop new promotional materials that can be useful or relevant to you. You will always be provided with an opportunity to opt out of receiving such communications. For example, You opt out by following the instructions located at the bottom of any commercial emails you may receive or by contacting us as described in the Contact Us section in this Privacy Notice.
For customer and third-party relationship management, including tracking emails, phone calls, and other actions you have taken as a prospective customer or our customer or other third party such as our space partners.
For aggregation or anonymisation of Personal Information, which is a format that does not allow our Administrators or Users to be personally identified. We use the resulting information for statistical analysis regarding the use of the Services, such as better to understand our customer base, or for other purposes.
For administrative and legal purposes, such as for compliance purposes, including enforcing our Terms & Conditions or enforcing or defending other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency, and to comply with our legal obligations and internal policies as permitted by law.
For safety, security and integrity, with a focus on investigating in good faith the alleged violation of our Terms & Conditions .

5. Who We Share Personal Information With

We may disclose Personal Information about you under the following circumstances:

Group Entities. We may disclose Personal Information about you to our affiliates and subsidiaries, if any, for the purpose of providing the Services and conducting business.
Service Providers. We work with third parties for the purpose of providing the Services such as hosting, maintenance, and support.

These third parties may have access to or process your Personal

Information as part of providing those services to us. For example:

We use service providers such as payment providers to process credit card payments on the PONT Platform. When you use a credit card to pay for our Services, information such as your name, billing address, phone number, email address, and credit card information will be submitted to service providers for verification and to manage any payments.
We use cloud service providers whom we rely on for data storage and disaster recovery and to perform our obligations to you.
We use service providers of business communication tools.
We use space partners who are service providers offering third-party spaces to be reserved via the PONT Platform.
Native Integrations. You can use native integrations to share data with other work applications. PONT does not share data from integrated apps with any other services or clients. For example, when you integrate your Google account, we access it to gather information that is required for the integration endpoint.
Change of Corporate Ownership. Personal information about our Administrators or Users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Legal. Personal information about our Administrators and Users will be disclosed to law enforcement agencies, regulatory bodies, and public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of PONT, our Administrators or Users, a third party, or the public.
Strategic Business Partners. We may share your Personal Information with our strategic business partners for the following purposes:
Expanding our sales and marketing efforts,
Expanding the number of spaces available via the PONT Platform,
To integrate PONT Platform via API into a specific organisation's IT infrastructure,
To embed the PONT Platform into a device,
To add features and functionality to the PONT Platform for resale to a unique customer-base, and
To offer “white label” versions of the Services under a different brand, such as Brave.

Your personal information will only be shared with a strategic business partner if you have a direct relationship with the strategic business partner. For example, if you book a space via a white-label offering, your personal information will be shared with that strategic business partner, and their privacy notice will apply.

6. Sub-processors

To provide and improve our services, we engage with several sub-processors. A sub-processor is a third-party data processor engaged by PONT, who has or potentially will have access to or process Personal Data. Personal Data is used to help us provide our services, and we ensure that these sub-processors comply with high data protection standards.

Current List of Sub-Processors

Stripe

Purpose: Payment Processing
Location of Processing: [Specify the location if known/applicable]
Description: Stripe is our payment processing partner. They handle all aspects of payment processing for transactions within our app, ensuring secure handling of credit/debit card information.

Microsoft Azure

Purpose: Hosting Services
Location of Processing: Europe and the United Kingdom
Description: Microsoft Azure provides cloud hosting services for our app, ensuring reliable and secure storage of our data and infrastructure. Our hosting location is specifically in Europe to comply with regional data protection laws.

Visitor API

Purpose: Analytics
Location of Processing: New South Wales, Australia
Description: Visitor API collects and analyses data on how our users interact with our app. This information helps us to improve app functionality and user experience.

Changes to the List of Sub-Processors

We may, from time to time, appoint new sub-processors or change existing ones. Such changes will be updated in this policy. We encourage you to review this list periodically to stay informed about our use of sub-processors.

If you do not agree with the changes, you may terminate your use of the PONT Platform in accordance with the PONT Platform Terms & Conditions .

7. Your Rights

You have the following rights associated with the processing of your personal information:

Right to Access or Right to Know. You have the right to obtain access to the Personal Information we hold about you and to request certain information about our processing. You have the right to receive an explanation of (i) why we process your Personal Information, (ii) the categories of Personal Information we have about you, (iii) who we share your Personal Information with, (iv) how long we store your Personal Information and (v) who we received your Personal

Information from if it was not collected from you directly. We will also inform you about your privacy rights.

Right to Rectification or Correction. You have the right to correct, update or complete any Personal Information we hold about you that needs to be updated or completed. Please note that we may rectify or remove incomplete or inaccurate information at any time and at our own discretion.
Right to Erasure or Deletion. You may request to have your Personal Information anonymised, erased, or deleted, as appropriate. In this case, if there is no overriding legitimate interest to continue processing your Personal Information, we will erase your data.
Right to Object to Processing. You have the right to object to our processing of your Personal Information where we rely on a legitimate interest or if we are processing your Personal Information for direct marketing purposes.
Right to Restrict Processing. You have a right, in certain circumstances, to stop us from processing your Personal Information other than for storage purposes.
Right to Portability. You have the right to receive, in a structured, commonly used, and machine-readable format, Personal Information that we hold about you if we process it based on our contract with you,

or with your consent, or to request that we transfer such Personal Information to a third party.

Right to Withdraw Consent. You may withdraw any consent you previously provided to us regarding processing your Personal Information at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdraw your consent.
Right to Lodge a Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. Please note that PONT operates under UK jurisdiction and complies with UK laws; any disputes will be solved by the court in the location where PONT is registered (UK).
Right Against Discrimination. We will not discriminate against you for exercising your rights.
Right to Opt-Out of Targeted Advertising or Sale. You can ask us to stop using your personal information for targeted advertising when required by law.

You may exercise these rights by contacting us at [email protected]

Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights. Subject to certain restrictions, you can ask an agent to exercise your rights for you. If you have an agent exercising your rights, that person must provide us with your written authorisation, allowing them to make such a request on your behalf. We reserve the right to deny the agent’s request if we cannot reasonably confirm proper authorisation and/or verify your identity as the requestor.

To appeal any refusal by us to act on a data subject rights request by contacting us by email at [email protected]

8. Retention of Information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy, to make the Services available to you, or as instructed by you, unless a longer retention period is required or permitted by law.

9. Security and Storage

We implement a variety of security measures that are reasonably designed to protect the safety of your Personal Information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction when you enter or submit your Personal Information on the PONT Platform. This includes, but is not limited to, encryption, firewalls, and secure server facilities. Our security protocols are regularly reviewed and updated to safeguard your data against unauthorised access, loss, or destruction.

However, no Internet or email transmission is ever 100% secure or error-free as it depends on multiple factors on both sides of the communication. Please remember this when disclosing any information to us via the Internet. If you believe your privacy has been breached through the use of the services, please get in touch with us immediately at [email protected].

When you use the Services, your personal information will be stored in the United Kingdom and/or European Union.

10. International Data Transfers

If you provide us with your Personal Information when using the Services from the USA, Turkey, Switzerland, or other world regions with laws governing data collection and use that may differ from UK or European Union law. Please note that you are transferring your Personal Information outside of those regions to the UK and European Union for storage and processing.

If we transfer your personal information internationally, we will ensure that relevant safeguards are in place to protect it adequately. We will comply with applicable data protection laws by relying on an EU Commission or UK adequacy decision or the current standard contractual protections for transferring your Personal Information or if a derogation is available.

Your privacy is paramount to us. We ensure that user consent is obtained before collecting any personal data.

11. Analytics & Advertising

Analytics. We will use first-party analytics to provide the Services, including analysing the performance of the PONT platform for product improvement or for marketing purposes as described above. We may also use third-party web analytics services on the PONT Platform, such as Google Analytics and Firebase. These third-party services use the technology described in the “Information We

Collect Automatically” section above to help us analyse how Users use the PONT Platform, including by noting a third-party website from which you arrive or actions users perform in the app. The information collected by the technology will be disclosed to or collected directly by these third parties, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described above. By using the app, you agree to the use of those tracking tools.

Advertising. Third-party services, including Google Analytics, Hubspot and LinkedIn, may use cookies and web beacons to collect information about your activities on the PONT Platform to provide you with targeted advertising based on your interests. This means these third-party services may show our ads on sites across the Internet based on your previous visits to the PONT Platform. Together with these third-party services, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to the PONT Platform.

The use of tracking technologies by third parties, technology partners or other third-party assets (such as social media links) on the site is not covered by this Privacy Policy. We do not have access to or control over these technologies.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices.

Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you must renew your online display advertising opt-out choice. To opt out of Google Analytics for Display Advertising or customise Google Display Network ads, you can visit the Google Ads Settings page .

12. Third Party Links and Websites

This Privacy Notice does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which the PONT Platform links. The inclusion of a link on the PONT Platform does not imply that we or our affiliates endorse the practices of the linked website.

13. Children’s Online Privacy Protection Act Compliance

Our Services are all directed to people at least 18 years old. We do not knowingly collect any “Personal Information” from anyone under 18 years of age. If we become aware that we have collected the Personal Information of an individual under 18 years of age, we will take reasonable steps to delete it as soon as possible.

14. Change of Ownership

In the event of a change in ownership or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all your Personal Information to that entity. We will use reasonable efforts to notify you of a transfer to an unaffiliated third party (by posting on our homepage or by emailing the email address that you provided to us, as chosen by us at our discretion).

15. Changes to Our Privacy Policy

We reserve the right to amend this privacy notice at any time to reflect changes in the law, our data collection, use or sharing practices, or technological advances.

We will make the revised Privacy Policy accessible throughout the PONT Platform. You should review this privacy notice periodically. The “Date of Last Revision” included at the beginning of this privacy notice will indicate when it was last updated.

By continuing to access or use our PONT Platform, you confirm you have read and understand the latest version of this Privacy Policy.

16. Complaints

If you wish to lodge a complaint about how we process your Personal Information, please get in touch with us as described in the Contact Us section below. We will endeavour to respond to your complaint as soon as possible.

You have the right to contact the appropriate supervisory authority at any time to lodge a complaint regarding the processing of your data. The list of EU supervisory authorities is located here. All other supervisory authorities can be located via a search for their website homepage.

You have the right to access, rectify, or delete your personal data stored with us. If you wish to exercise these rights, please get in touch with us. We are committed to responding to your request promptly and efficiently.

17. Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please get in touch with us by one of the following methods:

Send us an e-mail at: [email protected], or
Write to us at 23a Sandy Lane, Church Crookham, Fleet, England, GU52 8LA