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Occidental Privacy Policy

Last updated: December 29, 2021

Occidental Management and our affiliates (collectively “Occidental,” “we,” “us,” or “our,”) care about your privacy. This Privacy Policy (“Policy”) describes how Occidental collects, uses, discloses, and otherwise processes your Personal Information in connection with your use of our websites and applications (‘Website Services”), or other services that refer to or link to this Policy (collectively our “Services”).

Before you use our Services, please read this Policy in its entirety, to help 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 means reasonably available to us.

Our Services.  The Services referenced in this Policy include use and access of the website and application (Website Services) or other services provided by Occidental

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

2. INFORMATION WE COLLECT

The Personal Information that we collect, and our use of that information depends 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 company, 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;
  • If you opt-in to certain features or depending on your device settings, we obtain geo-location data and information about your contacts;
  • from third parties such as our building managers, licensees and property brokers); and
  • that we obtain from other sources, including data brokers or information providers (such as Dun & Bradstreet).

INFORMATION COLLECTED FROM YOU

Occidental requests different types of Personal Information from you and your company or others, 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 and other Identifiers, including your name, mailing address, phone number, email address, and other information that enables us to contact you;
  • Verification Information, including your personal photograph, photo ID or government issued identification, and date of birth;
  • Professional and Employment-Related 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;
  • Email Calendar Information, when we integrate with your corporate email calendar (e.g., Gmail or Microsoft Outlook) and collect data regarding the conference rooms you book;
  • Utilization Information, including how frequently you visit, how long you stay, and what types of Services you use when you visit a Occidental location. These include services such as printer or Wi-fi usage, and desk or conference room bookings;
  • Communications, and any other information that you intentionally share, send, or receive using the Services, including your e-mail, SMS, Slack, requests made through feedback platforms, calendar invitations, and any other information you choose to share with us — including your photos, videos, blog entries, interests, hobbies, and groups with which you are affiliated — and that you send or receive using the Services;
  • Device and Usage Information, including information about your computer or device and Internet or other electronic network activity information. This includes:
  • Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address.
  • Geolocation information, such as through your mobile device’s GPS signal or WIFI signal, and information about your contacts, depending on your device settings;
  • Information about your online activity, including information collected through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, and your offline activity, including information about events you attend at Occidental locations; and
  • Other Personal Information, including, in addition to all of the information described above, instant messenger and social media screen names, usernames and passwords, relationship to emergency point of contact, vehicle identification, and other details such as the time and purpose of your visit, photos of you, 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 Information included in content and information that you add to your member network or other community profile.

INFORMATION COLLECTED ABOUT YOU

  • Social Media. Occidental collects Personal Information to enable you to use online social media resources. If you register or log into your account through a third-party social media service, we will have access to some of your account information from that service, such as your name and other information in that account, as authorized by your settings on that service. You have the ability to disable the connection between our Services and your third-party social media account(s) at any time.
  • Third-Party Sources. We obtain Personal Information about you from your company, broker, parent or guardian, or from your host if you are a visitor or guest on our campus. We also may receive your Personal Information from publicly and commercially available sources, as permitted by law. If we obtain Personal Information about you from a third party, we will confirm that the Personal Information is from a legitimate source.
  • Google and Other Third-Party Analytics. We use a tool called “Google Analytics” to collect information about the 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 visiting 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. You can learn more about how Google Analytics collects and processes data and opt-out options at http://www.google.com/policies/privacy/partners/. We also may use other third-party analytics tools to collect similar information about use of certain online Services.
  • “Do Not Track.” If you have enabled the feature, your web browser may transmit “do-not-track” signals to our websites and other online services with which your browser communicates. We currently do not take any action in response to these signals.
  • 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 may 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, Occidental 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 Occidental to enable you to access your user accounts and to enable Occidental to track use of these tools. Some of these tools enable you to e-mail reports and other information from the tool.

ANONYMOUS, AGGREGATED, AND OTHER INFORMATION

We also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us or through the Services, in accordance with any applicable agreements between you or, if applicable, your company, including, for example, trademarks, logos, and other intellectual property you own.

In addition, we collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in 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.

USE OF COOKIES

The Website Services use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Occidental pages, or register with Occidental site or services, a cookie helps Occidental to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Occidental Web site, the information you previously provided can be retrieved, so you can easily use the Occidental features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Occidental services or Web sites you visit.

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, including online and offline events, and other materials you request;
  • protect against fraud, abuse, or harm and to otherwise provide a Secure Environment (“Secure Environment” as used in this Policy means both physical and online environments);
  • respond to or fulfill customer service requests;
  • analyze, better tailor, and improve our products and Services;
  • contact you about our Services, promotions, and sweepstakes, tailor and provide you with relevant advertising, enhance your engagement with us, and otherwise communicate with you through various means, which may include by email, telephone, post, or by other means as communicated to you from time to time; and
  • comply with our legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

LEGAL BASES FOR PROCESSING PERSONAL INFORMATION IF RESIDENT IN THE UK AND EU

The processing of your Personal Information as described above is necessary to meet our contractual obligations to you or your company, to meet our legal obligations, or to meet our legitimate interests in providing our Services. Our legitimate interests may include providing you and others with a secure environment, analyzing, improving, and better tailoring our products and Services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.

We also 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 promotions or sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt-out of receiving all such communications (unless they are transactional solely related to the provision of our Services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in Section 5 of this Policy.

4. SHARING OF PERSONAL INFORMATION

We disclose your Personal Information in limited circumstances to Occidental, our community, our service providers and advertisers, other end users, in order to provide our Services and to improve ways of working in our community and where required by applicable law. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent. We will require all parties receiving your Personal Information to take appropriate measures to protect your Personal Information and to process your Personal Information only for the purposes described:

  • Among Occidental. We may share your Personal Information among Occidental entities depending on where you are located and the Services that you use. Occidental uses your information in accordance with this Policy, and we share this information for our administrative purposes including activities such as IT management, for them to provide services to you, or to support and supplement the Services that we provide.
  • Suppliers and Vendors. We rely on various third-parties to perform a variety of services on our behalf and to help us grow and improve our business. We take steps to ensure that where we share your Personal Information with these third parties that they act only in line with our instructions and on our behalf, or otherwise use Personal Information as described in this Policy.

Property Management.  In some cases we may share your Personal Information with our property management at Occidental so that they can effectively manage and operate the building or buildings in which it manages.

  • Licensees. We share your Personal Information with our licensees, for the purposes described in this Privacy Policy, such as providing and personalizing the products and services and fulfilling your requests.
  • Research / Survey Solicitations.  From time to time, we will share your Personal Information 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.
  • Third-Party Advertising Partners.  We share limited Personal Information with third parties that serve our advertising online, so that they can display our advertisements to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively.
  • 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 request;
  • to comply with our legal obligations, including with auditors, lawyers, CPAs, financial consultants, or other consultants;
  • to comply with applicable law or respond to a 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 the Occidental companies, business partners, members, or employees; and
  • where otherwise required by applicable 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.
  • 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.

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.

We, as well as certain of these third-party partners may use tracking tools (e.g., cookies, web beacons, and Internet technologies) to collect information regarding your activities (e.g., your IP address or page(s) visited). We also may 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-Occidental related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.

4.2 SOCIAL MEDIA

We are active on social media (e.g., Twitter, Facebook, etc.) and share information, images, and videos 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:

  1. request confirmation of whether we store, use, or share any of your Personal Information and be informed about third parties with whom your Personal Information has been shared;
  2. obtain access to or a copy of your Personal Information;
  3. receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
  4. restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;
  5. seek correction of inaccurate, partial, untrue, or incomplete Personal Information; In some cases, we may provide self-service tools that enable you to update your Personal Information;
  6. request erasure, anonymization, or blocking of Personal Information held about you by Occidental, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
  7. withdraw your consent to our processing of your Personal Information. If you refrain from providing Personal Information or withdraw your consent to processing, some features of our Service may not be available.

If you would like to exercise any of these rights, please contact us at the physical address set forth below.

We will process all such requests in accordance with local laws. To protect your privacy, Occidental will take steps to verify your identity before granting access or making any changes to your Personal Information. The California Privacy Rights section below provides additional information for California residents.

6. OPT-OUT and WITHDRAWAL OF CONSENT

You may have the right to opt-out or withdraw your consent for certain uses and disclosures of your Personal Information.

6.1 SENSITIVE PERSONAL INFORMATION

Where you have consented to Occidental’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 may withdraw that consent, in accordance with applicable law.

Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Personal Information for a purpose other than its original purpose or a purpose authorized subsequently by the data subject, Occidental 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, Occidental will comply with the law or contract.

6.2 EMAIL AND TELEPHONE COMMUNICATIONS

  • Opting Out of Marketing Communications.  We will 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 Occidental 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.

7. COMPLAINTS AND SUPERVISORY AUTHORITY

If you would like to make a complaint or if you have any questions about how we use or keep your Personal Information, you may contact Occidental at privacy@occmgmt.com.

8. INTERNATIONAL TRANSFERS

Occidental is headquartered in the United States. Your information will likely be collected in your country and subsequently transferred to 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 contractual 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 forth below.

9. RETENTION

We retain the personal information we receive for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

10. INFORMATION SECURITY

Occidental 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. By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

11. OTHER RIGHTS AND IMPORTANT INFORMATION

11.1 COLLECTION OF INFORMATION FROM CHILDREN

Generally, our Services are not directed to children, and we do not knowingly collect Personal Information from children except as permitted under applicable law. If we become aware that a child has provided us with Personal Information, we will delete such information from our files or obtain parental consent in accordance with applicable law.

11.3 THIRD PARTIES

This Privacy Policy does not address the privacy, data, services or other practices of any entities other than Occidental, including property managers, licensees and brokers.

We may display advertisements and other content from third parties or partners that link 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. Additionally, third parties may sell goods or offer services at our facilities or in combination with our Services. We are not responsible for those third parties’ services or their privacy practices.

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-parties     .

11.4 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 “Last Updated” date to indicate when those changes became 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 Occidental.

11.5 QUESTIONS OR COMMENTS

If you have any questions or comments regarding this Policy, please contact us at privacy@occmgmt.com.

If you are based in a jurisdiction where the law requires that Occidental has a Data Protection Officer, please submit your query to privacy@occmgmt.com.

You may also direct inquiries in writing to:

Brian Burris
Chief Legal Officer
316.262.3331
8111 E. 32nd St. N., Suite 101
Wichita, KS 67226

Occidental 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.

12. CALIFORNIA AND CCPA-SPECIFIC INFORMATION

Your California Privacy Rights:  California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits the Company’s customers who are California residents to request and obtain from the Company once a year, free of charge, information about the personal information (if any) the Company disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the Company shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:

Brian Burris
Chief Legal Officer
316.262.3331
8111 E. 32nd St. N., Suite 101
Wichita, KS 67226