Incubase, LLC (“Incubase Workspace “we,” “us,” or “our”) knows you and our User’s or Guest’s or Member’s (“you” or “your”) personal information is important. We appreciate the trust you place in us when you visit the Incubase website and use 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 the Incubase website (“Website”). When you leave the Incubase Website, this Privacy Notice no longer applies. Any subsequent website, application, or service you access will have its own privacy notice and other applicable terms.

This Policy tells you about your rights and choices with respect to 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 Incubase Workspace on behalf of your Users you must provide notice to your Users and this Privacy Policy 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 Incubase Website you must provide notice to your Users regarding how you are processing the personal information, and this Privacy Policy must be incorporated into your privacy notice.

When you visit the Incubase Website, 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, our Guests or our 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 Incubase Website.

• Account Information. If you create an account to use the Services by accepting the invitation to register as a Guest, User or a Member (“Member”), 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, job title, photograph (optional), geolocation, booking history, and other account information necessary to create and maintain your account.
• Contact Information and Other Information You Choose to Provide to Us. You can provide a variety of 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. We will use that information solely for the purpose of fulfilling your purchase request.
• 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 Incubase Website (“User Content”).

Information Collected Automatically

We may automatically collect certain information based upon your behavior on the Incubase Website. We use this information to conduct internal research on system usage, demographics, interests, and behavior to better understand who is visiting the Incubase Website, for marketing purposes and to improve our Services. Whenever possible, the collected data is de-identified, aggregated and/or anonymized.

• Single Sign-On Through Internet Service Providers. We may collect Personal Information from internet service providers when you decide to use their single sign-in servers to connect to our Services. Your interactions with these tools are governed by the privacy notices of the corresponding platform.
• Device and Usage Information. When you access and use the Incubase Website, 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 Incubase Website 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 Incubase Website. 
• 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 Policy.

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 to operate, maintain and support our Services by making available our online database with business contact details to Administrators and Users.
• For personalization to customize our Services to meet your specific needs.
• For product improvement as described in our Terms of Service and other collateral documentation 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 otherwise provide customer support.
• Subject to any consent requirements, to send marketing materials, alerts about the latest developments and features or other promotional materials, and to 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 Policy.
• For customer and third-party relationship management including to track 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 anonymization 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 to better understand our customer base, or for other purposes.
• For administrative and legal purposes, such as for compliance purposes, including enforcing our Terms of Service 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 focused on investigating in good faith alleged violation of our Terms of Service.
  

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 is inaccurate or incomplete. 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 anonymized, 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 are relying 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 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 the processing of 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 withdrew 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.
• Right Against Discrimination. We will not discriminate against your 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 as set out in the “Contact Us“ section below.

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 to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization 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 privacy@incubase.co.

PLEASE NOTE: Only the registered account Administrator may close an account. The Administrator may decide to terminate the ability of one or more of the invited Users to use their account. Only the User’s manager may request the deletion of the User Content in the account.

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

We implement a variety of security measures that are reasonably designed to protect the safety of your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction when you enter or submit your Personal Information on the Upflex Platform. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to us via the Internet. IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF THE SERVICES, PLEASE CONTACT US IMMEDIATELY AT: privacy@incubase.co.



When you use the Services, personal information about you will be stored in the United States.

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

If our Website links to other websites that include our branding, this Privacy Policy does not apply to those other websites. Visitors to those websites are advised to carefully read the notices on those individual websites.

Our Services are all directed to people who are at least 18 years old or older. We do not knowingly collect any “Personal Information” (as defined by the U.S. Children’s Online Privacy Protection Act) 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.

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 a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).

If you wish to lodge a complaint about how we process your Personal Information, please contact us as described in the Contact Us section below. We will endeavor to respond to your complaint as soon as possible. You may also lodge a claim with the applicable supervisory authority.

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

• Send us an e-mail at: privacy@incubase.co, or
• Via the Contact Us web form located on the Incubase Website.