View the Space, Inc. ( “VTS” or “We”) respects your privacy and is committed to protecting it through a comprehensive framework of protections that apply regardless of which of our services you may use. All VTS operations are designed and implemented to comply with applicable data protection laws, including the California Consumer Privacy Act of 2018 (as amended, the “CCPA”), the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). As a US company, VTS is subject to the investigatory and enforcement powers of US regulatory and legal authorities, including the Federal Trade Commission.
This policy describes the types of information we may collect from you or that you may provide when you visit websites managed by VTS (our “Websites“), use the VTS, Rise, or Activate platforms, or use the VTS, Rise, or Lane mobile applications (collectively the “VTS Properties”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using VTS Properties, you agree to this privacy policy.
This policy applies to information we collect:
Through VTS Properties; and
In email, text, and other electronic messages between you and VTS.
It does not apply to information collected by:
Offline communication with VTS parties or through any other means outside of the VTS Properties; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or on a VTS Property.
Information we collect about you and how we collect it
We collect several types of information from and about users of VTS Properties, including information:
By which you may be personally identified, such as name, postal address, e-mail address, photos that you may choose to upload, and telephone number (“Personal Data“); and
About your internet connection, the equipment you use to access VTS Properties, and information about how you interact with the VTS Properties, such as page views.
We collect this information:
Directly from you when you provide it to us by filling in forms or uploading files within VTS Properties, by sending correspondence to us, or by inputting data through the VTS Properties.
Automatically as you navigate through the VTS Properties. Information collected automatically may include usage details, traffic data, location data, logs, other communication data and the data regarding the resources that you access and use on the VTS Properties, and information about your computer and internet connection, including your IP address, operating system and browser type.
We collect this information because it’s either directly necessary to provide our services (for example, we need an email address to establish an account in a VTS Property) or because it’s useful to help us improve the Websites and VTS Properties (for example, seeing which pages or modules see more or less use so we can improve the experience).
Your opt-in will be required for any automatic data collection that isn’t for VTS internal analytics or necessary for your use of the VTS Properties. The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.
How we use your information
We use information that we collect about you or that you provide to us, including any Personal Data:
To present VTS Properties and their contents to you;
To verify your identity;
To provide you with information, products, or services that you request from us;
To present information sent by you to administrators through the VTS Properties;
To improve the VTS Properties by storing information about your preferences, customizing elements of the VTS Properties to your interest, speeding up your searches, and recognizing you when you return to the VTS Properties;
To provide you with notices about your account;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
To notify you about changes to the VTS Properties or any products or services we offer or provide though it;
To allow you to participate in interactive features on VTS Properties;
To provide you with support and respond to queries;
In any other way we may describe when you provide the information; and
For any other purpose for which you provided the information, or otherwise with your consent.
If you make a reservation or complete a transaction with a third party using a VTS Property, we record the transaction and share necessary information with the third party to ensure it can be processed and managed by that third party. If you enable location-based services, then we may use your GPS location to provide location based information to you as part of the VTS Property. We do not store GPS data or use it for any other purposes. Some functions within certain VTS Properties allow you to send invitations to third parties; when you use those functionalities the VTS Property may request access to your contacts to populate those invitations.
You may receive advertising of third party products or services through the VTS Properties based on your profile and use of the VTS Properties. For example, if you are a use of the Activate or Rise platforms, you might receive a notification of a sale at a store in the building where you work or a notice that a fitness center has opened on site. We do not permit any advertising that isn’t directly related to the platforms themselves.
VTS will only use your Personal Data in ways that are compatible with the limited purpose for which it was collected, unless we receive your permission otherwise. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for, or that you later authorized, we will provide you with the opportunity to opt out of such usage. We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
Sharing of your information
As a user, you may have the ability to access third party pages within the VTS Properties. When interacting with those pages, your information will be shared with those third parties based on that interaction. For example, if you reserve an amenity in a building, you will be identified to the building manager as the user making the reservation.
We may disclose aggregated and anonymized information about our users that does not identify any individual, without restriction.
We may disclose Personal Data that we collect, or that you provide, as described in this privacy policy:
To our subsidiaries and affiliates;
Where the VTS Property is an application managed by a third party, to that third party for the use of the VTS Property;
To contractors, service providers, and other third parties we use to perform functions on our behalf and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VTS’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by VTS about users of the VTS Properties is among the assets transferred;
To fulfill the purpose for which you provide it; and
With your consent.
For example, if you are using the Activate application to attach a photo to a work order request for your building administrator, that administrator will be able to view the work order request and photo.
We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our obligations and to stop and remediate any unauthorized processing. Our relationships with third parties do not change our obligations under this policy; whenever we transfer your personal information onwards, we retain liability and responsibility for ensuring that any and all onward processing is done in a compliant manner in line with this policy and the DPF Principles and shall remain liable unless and until we can prove that we are not responsible for the event giving rise to the damage.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any valid government or regulatory request;
To enforce or apply our terms of use and other agreements, including for billing and collection purposes;
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VTS, our customers, or others.
Data processing and the GDPR
The General Data Protection Regulation 2016/679 (the “GDPR”) is a European privacy law applicable to citizens of the European Economic Area. Data input into VTS Properties is known as “Platform Data.” Under the GDPR, VTS is a Data Processor of VTS Platform Data. Users of the VTS software are the Controllers of Platform Data and are responsible for all Controller obligations, such as choosing the appropriate legal basis for collecting and using tenants’ personal data. VTS complies with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. VTS has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. VTS has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Data controlling and the GDPR
VTS collects, stores and processes business contact data (used for direct marketing, demonstrations, and business development) and user usage data (used for internal analytics, user experience tracking, and marketing purposes). Under the GDPR, VTS is a Data Controller with regards to certain business contact data and usage data. Business contact data is obtained by VTS on the basis of your consent (where you affirmatively provide it to VTS, for example when requesting a product demonstration) or for our legitimate interest in responding to your queries, assisting you in your use of the VTS Properties, and otherwise communicating with VTS users, customers, and potential customers. User usage data is obtained for the purpose of providing customer support, improving the VTS Properties, and communicating with VTS customers or potential customers. Individuals can opt out of the use of business contact data at any time by making a request to privacy@vts.com. User usage data is a part of the VTS platform, so when an individual would like to opt-out of collection of usage data the individual will no longer be able to use the VTS platform.
Accessing, correcting your information and exercising privacy law data rights
Whether it’s the GDPR, the CCPA, or other statute, VTS is committed to complying with all applicable law in the way it handles personal information. VTS operations are based in the United States, which is the geographic location for all VTS data processing.
You can review and change your personal information by logging into the particular VTS Property and visiting your account profile page.
You may also send us an email at privacy@vts.com to request access to, correct, or delete any personal information that you have provided to us, or request execution of the following rights:
Receive a copy of your personal data;
Correction of your personal data;
Deletion of all of your personal data;
Restricting or ending the use or processing your personal data for a particular purpose;
Obtaining a copy of your personal data in a machine-readable ‘open format’ (e.g., XML, JSON, CSV, text file format); or
Opt out of automated decision making.
Please note that VTS engages in no automated decision making. VTS cannot delete all of your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In the event that you do not opt to have your data deleted, VTS may retain your Personal Data only for so long as we have a legitimate business purpose to use that data, but in no event longer than seven years from your last interaction with VTS.
Third-Party data controllers
We utilize a number of third party providers to assist with various parts of the technology used to provide our services. We enter into written contracts with any and all third-party providers requiring them to provide the same level of protection for Personal Data as we do. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received.
Business Transfers
In the event that VTS is involved in a corporate reorganization or transaction, we may assign all of our data (which includes your Personal Data) to a new entity as a result.
Data security
While we can’t guarantee that any practice is 100% secure, we have implemented industry standard measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to a VTS Property, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to VTS over the internet. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on VTS Properties.
Questions or complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at privacy@vts.com. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, VTS commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact VTS at the email address above. We will investigate resolve any complaints, disputes, or rights request regarding the use or disclosure of your Personal Data within thirty (30) days of receiving your inquiry.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, VTS commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, VTS commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither VTS nor JAMS resolves your complaint, you may have the possibility, under certain conditions, to invoke binding arbitration through the Data Privacy Framework Panel.
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you either by email to the email address specified in your account and/or through a notice on the Websites, platform, or application home page. The date the privacy policy was last revised is identified at the top of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this privacy policy to check for any changes.
Last updated on January 8, 2024