Privacy Policy

Prro Global Privacy Policy

Effective Date: Feb. 12, 2018

Prro, LLC, a California Limited Liability Company and an indirect, wholly-owned subsidiary of

Renesent, Inc. and our affiliates (collectively, “Prro,” “we,” “us,” “our,” or “Prro Family”) cares

about your privacy. We are committed to maintaining your trust by protecting your Personal

Information. This Privacy Policy (“Policy”) describes how the Prro Family collects, uses, and

discloses your Personal Information in connection with the use of our websites (“Website

Services”), applications (“apps”), or other service that refers to or links to the Policy, as well as

any offline products, programs, courses, and services (collectively our “Services”).

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, which helps 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 any means reasonably available to us.

Our Services. The Services referenced in this Policy include the Services provided by the Prro

Family. You can read more about how Personal Information is used by each Service, by clicking

on the name of the Prro Family company whose Services, websites, or applications you use

below.

References to “you.” In this Policy, “you” means anyone who uses our Services, websites, or

applications. If you are an Employee or Applicant, the Prro Privacy Policy for People Data

explains how we use Personal Information in the context of our employment relationship with

you. If you are an Employee or Applicant that uses our Services, this Policy explains how we use

Personal Information in the context of your use of our 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.

 

2. INFORMATION WE COLLECT

The Personal Information that we collect and how we use that information depend 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 employer, 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. For more

information about these technologies, please see our Cookie Policy;

  • that we obtain from other sources; and
  • If you opt in to certain features, we obtain geo-location data, photos and information

about your contacts.

INFORMATION COLLECTED ABOUT YOU

Prro and our family of companies request different types of Personal Information from you,

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, including your name, mailing address, phone number, email

address and other information that enables us to contact you;

  • Verification Information, including a photo ID or government issued identification, and

date of birth;

  • Professional 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;

  • Intellectual Property, including trademarks, logos, and other intellectual property that

you own;

  • Other Personal Information, including instant messenger and social media screen

names, usernames and passwords, relationship to emergency point of contact, vehicle

identification, and other details such as the purpose of your visit, 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 data included

in content and information that you add to your member network or other community

profile.

  • Email Calendar Information. We integrate with your corporate email calendar (Gmail or

Microsoft Outlook) and collect data regarding the conference rooms you book.

  • Office Preferences. You provide us with your office preferences, such as temperature,

fan speed, desk and chair height, desk location, phone booth, beverage, snack, and

other preferences related to the Services.

  • Communications. We also collect and store communications, such as e-mail, SMS, Slack,

requests made through Amazon Echo or similar technology, calendar invitations, 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.

INFORMATION COLLECTED FROM SOURCES OTHER THAN YOU

  • Social Media. Prro collects Personal Information to enable you to use online social

media resources, including 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 third-party account information from that service, such as your name and

other information in that account, as authorized in your settings on that service. You

have the ability to disable the connection between our Services and your third-party

account at any time.

  • Information from Third-Party Sources. We obtain Personal Information about you from

your company, organization, broker, parent, or guardian; or from your host if you are a

visitor or guest to one of our spaces. We also may receive information about you from

publicly and commercially available sources and other third parties as permitted by law.

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.

  • Google Analytics. We use a tool called “Google Analytics” to collect information about

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 coming to 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.

○ Learn more about how Google Analytics collects and processes data and opt-out

options at http://www.google.com/policies/privacy/partners/.

  • Information Used for Interest Based Advertising. Through the Website Services, we

allow third-party advertising partners to set tracking tools (e.g., cookies) to collect

anonymous, non-Personal Information regarding your activities (e.g., your IP address or

page(s) visited). 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-Prro related websites within their networks. This practice is

commonly referred to as “interest-based advertising” or “online behavioral advertising.”

For more information on these types of tracking tools, please see our Cookies Policy.

  • 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 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,

Prro 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 Prro to enable

you to access your user accounts and to enable Prro to track use of these tools. Some of

these tools enable you to e-mail reports and other information from the tool.

ANONYMOUS AND AGGREGATED INFORMATION

We also collect and/or generate anonymized and aggregated information from your use of the

Services. We use anonymized and aggregated information 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 Services, in order to meet our contractual obligations to you or

your company;

  • contact you about our Services, promotions, and sweepstakes. contact you about our

Services, promotions, and sweepstakes. We 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 these promotions or sweepstakes, where permitted by applicable law.

We ensure that we do not use your Personal Information in ways you would not expect

by allowing you to opt out of receiving all such communications (unless they are solely

related to the provision of our Services to you and have no marketing element) and,

where required by applicable law, we will not send any such messages without your

prior consent; and

  • comply with our legal obligations. Among other things, we use Personal Information to

comply with financial reporting obligations, or court orders, warrants, or subpoenas in

accordance with applicable law.

You can read about how each member of the Prro Family uses Personal Information when

providing its Services using the links below. Remember that in certain circumstances — in

particular where we use Personal Information on the basis of our legitimate interests or your

consent — and where permitted by applicable law, you have the right to object to our uses of

your Personal Information.

Prro, Renesent, Algorip and Powered by Prro

Products

Algorip

Renesent

Prro Labs

 

4. SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to the Prro Family, our

community, our service providers and advertisers, and other end users, in order to provide our

Services and to improve ways of working in our community. We do this for the purposes

outlined above. Where required by applicable law, we will only share your Personal Information

with particular third parties with your consent.

  • Among the Prro Family of companies. Our Services are provided by Prro and its family of

companies depending on where you are located and the Services that you use. The Prro

Family uses your information in accordance with this Policy.

  • Our Community. Our Services include online and offline member communities, forums

and networks that allow you to share information and connect with others. We make

this possible by creating profiles for members or permitting members to create their

own profiles. Such a profile contains your name and the name of your company or other

organization and other information you provide. Depending on the Services you use,

this profile might be created automatically and is accessible to other members of the

forum or network, some of which include all Prro members. You can supplement your

profile by adding additional information about yourself and your company or

organization, and by posting content and comments. You can share your profile with a

broader audience (e.g., via social media). Please note that we cannot control the actions

of other users of the Services with whom you share information.

  • Service Providers. We rely on third-party service providers to perform a variety of

services on our behalf, and we take steps to ensure that they act only in line with our

instructions and on our behalf, or otherwise to use Personal Information as described in

this Policy.

  • 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 or organization

request, or to auditors or consultants;

○ to comply with the law or respond to 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 our respective Prro

Family of companies, business partners, members or employees; and

○ where otherwise required by 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.

  • Third-Party Advertising Partners. We share limited Personal Information with third

parties that serve our advertising online, so that they can display our adverts to

individuals who may find them most relevant. We share this information in order to

meet our legitimate interests in advertising our products effectively. We make sure that

we only share limited Personal Information for this purpose, and only to trusted

partners that are restricted in how they can use your Personal Information.

  • 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.

  • Research / Survey Solicitations. From time to time, we will provide your Personal

Information to our service providers 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.

 

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.

  • Cookies and Other Internet Technologies. These third parties collect or receive certain

information about your use of our Services, including through the use of cookies, web

beacons, and Internet technologies. Check out our Cookie Policy for more information.

○ 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.

  • Public Forums. Our Sites may make member networks, chat rooms, forums, and/or

other groups available to the 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 disclose

online.

  • Social Media. We are active on social media (e.g., Twitter, Facebook, etc.) and share

information, images, and video 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

(i) request confirmation of whether we store, use or share any of your Personal Information; (ii)

obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of

Personal Information that you have provided to us, or ask us to send that information to

another company (the “right of data portability”); (iv) restrict our uses of your Personal

Information or, as described above, object to those uses; (v) seek correction of inaccurate,

untrue or incomplete Personal Information; or (vi) request erasure of Personal Information held

about you by Prro, subject to certain exceptions prescribed by law. If you would like to exercise

any of these rights, please contact us at the e-mail or physical addresses set out in section 12.5

below.

We will process such requests in accordance with local laws. To protect your privacy, Prro will

take steps to verify your identity before granting access, or making any changes to your

Personal Information.

 

6.OPT-OUT

You have the right to opt-out of certain uses and disclosures of your Personal Information, as

set out in this Policy, and in specific circumstances, for example related to direct marketing.

6.1 GENERAL

Where you have consented to Prro’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 are able

withdraw that consent at any time.

Prior to disclosing Sensitive Personal Information to a third party or Processing Sensitive Data

for a purpose other than its original purpose or the purpose authorized subsequently by the

Data Subject, Prro 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, Prro will

comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

  • Opting-Out of Marketing Communications. We 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 Prro 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.

6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE

Should Prro engage in interest-based advertising, it will endeavor to comply with the

cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the

Digital Advertising Alliance (DAA) (http://aboutads.info), as applicable. As part of this service,

Prro’s online advertisements may sometimes be delivered with icons that help Individuals

understand how their data are being used and provide options to restrict that use. To opt-out

of internet-based advertising by all DAA-participating companies, please visit

http://www.aboutads.info/choices/

 

7. SUPERVISORY AUTHORITY

For visitors to our Services in the EU, you may lodge a complaint with a supervisory authority if

you believe our processing of your Personal Information infringes applicable law.

 

8. INTERNATIONAL TRANSFERS

Prro is headquartered in the United States. Your information will likely be collected in your

country and subsequently transferred 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 data protection 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

below in Section 12.5. 9. RETENTION

Prro will retain your Personal Information for as long as you have a relationship with us, and for

a period after your relationship with us has ended.

When determining how long this retention period will last, 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 Prro is important to us. Prro 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. Unfortunately, no data transmission over the Internet

or storage of information can be guaranteed to be 100% secure. As a result, while Prro strives

to protect your Personal Information, we cannot ensure or warrant the security of any

information that you transmit to Prro, and you do so at your own risk. As such, we ask that you

help us be safer together by implementing your own security controls, such as a strong

password, not sharing your credentials or badge with others, logging out when you leave your

desk, and other security best practices.

 

11. AUTOMATED PROCESSING

We do not currently use your Personal Information in such a way that automated decisions are

made about you without any human input.

In the future, we may use automated processes to help us determine your eligibility for new

services, alternate space, or other business-related opportunities. In such cases, if and as

applicable, and to the extent required by applicable law, we will endeavor to implement

suitable safeguards, including, for example, an opportunity for you to request human

intervention, express your point of view, contest any decisions made, and request that we

restrict the use of your Personal Information for the purposes of these automated decisions.

 

12. OTHER RIGHTS AND IMPORTANT INFORMATION

12.1 CCTV

Prro’s buildings have CCTV installed to meet our legitimate business interests in protecting the

safety of Prro’s employees, members, and guests and their property, as well as to improve our

products and services, and to analyze how users navigate and use our spaces. These recordings

may be accessed by Prro and Members with a need to know. These recordings may be shared

with competent authorities in accordance with applicable laws, if required. The recordings are

retained for a limited period of time, but may be kept longer for the investigation of an incident

or when competent authorities request us to retain them.

12.2 COLLECTION OF INFORMATION FROM CHILDREN

Generally our Services are not directed to children under the age of 16, and we do not

knowingly collect Personal Information from anyone under the age of 16. Persons over 16 but

under 18 years of age should ask their parents for permission before using the Services or

sending any information about themselves to anyone over the Internet. If a parent or guardian

becomes aware that his or her child has provided us with Personal Information without

parental consent, he or she should contact us as described in section 12.6 below. If we become

aware that a child under 16 years old has provided us with Personal Information, we will delete

such information from our files.

If you enroll your child in WeGrow or Rise by We, we will only process their information with

parental consent.

12.3 LINKS

We display advertisements and other content from third parties or partners that links 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. 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-party websites.

12.4 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 “Effective Date” below to indicate when those changes will become

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 Prro.

12.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding our Policy, please contact us at:

Privacy

Prro LLC,

514 N. California Ave.

Beaumont CA 92223

Email: hello@Prro.co

Prro 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.

Effective Date: Feb. 12, 2018

 

13. Country Specific Information

California Privacy Rights

If you live in California, you may opt out of having your Personal Information shared with third

parties for those third parties’ direct marketing purposes by e-mailing privacy@Prro.co.

Some web browsers may transmit “do-not-track” signals to the websites and other online

services with which a user communicates. There is no industry standard that governs what, if

anything, websites should do when they receive these signals. We currently do not take action

in response to these signals. If and when a standard is established and accepted, we may revisit

our policy on responding to these signals.

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 privacy@Prro.co. 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.

China

Prro does not knowingly collect Personal Information from anyone under the age of 18 in China.

Singapore

By submitting your personal data to us, you consent to us collecting, using, disclosing and

processing your personal data in accordance with this Policy. If you have any questions please

contact our Data Protection Officer at DPO.Singapore@Prro.co.

South Korea

We process Personal Information only within the scope specified as the period for which such

Personal Information is held and used in South Korea. Once the purpose of holding Personal

Information has been satisfied, or the period for holding such Personal Information has expired,

such Personal Information will be destroyed.

Membership Information. One year from termination of membership, provided, however, this

period may be extended if we notify you of the purpose of the extension, the length of the

extension period, and the nature of Personal Information to be retained during such period and

if you agree to such extension.

Record of cancellation of contracts or subscription. Five years from termination of membership.

Record of payments and supply of goods. Five years from termination of membership.

Record of customer complaints or dispute settlements. Three years from termination of

membership.

When Personal Information is no longer required due to the expiration of the Personal

Information holding period, or the purpose for which the Personal Information has been

obtained has been achieved, we will promptly destroy the Personal Information. If applicable

laws require us to continue to store this Personal Information, we will transfer such information

to a separate database or place in a separate storage compartment.

Establishment of destruction plan selection and confirmation of Personal Information

(Personal Information files) to be destroyed approval from the Personal Information

protection manager destruction.

We destroy electronic files containing Personal Information by permanently deleting files in a

manner in which they cannot be restored. We destroy files in other media, including paper

documents, by shredding.